- 11 - with petitioner, the fact remains that respondent complied with the statutory requirements in notifying Mr. Olson about the Computer Graphics' partnership proceeding and, thus, is deemed to have properly notified petitioner of such proceeding. Because petitioner was properly notified of the partnership level proceeding regarding Computer Graphics, we hold that the affected items notice of deficiency is valid as to her. Jurisdiction Regarding the Innocent Spouse Defense In her petition, petitioner claims that she is entitled to innocent spouse relief under section 6013(e) with respect to not only the additions to tax determined in the affected items notice of deficiency, but also the computational adjustment that respondent assessed against her on August 29, 1994. Respondent acknowledges that petitioner is entitled to raise the innocent spouse defense with respect to the additions to tax determined in the affected items notice of deficiency. However, respondent contends that this Court lacks jurisdiction in an affected items proceeding to consider the innocent spouse defense with respect to a computational adjustment. We agree with respondent. As previously mentioned, this Court has no jurisdiction to consider challenges to computational adjustments in an affected items proceeding. Bradley v. Commissioner, supra; Saso v. Commissioner, supra; Maxwell v. Commissioner, supra, Palmer v.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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