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Commissioner, supra. In the instant case, petitioner is directly
challenging the computational adjustment made pursuant to the
dismissal of the partnership proceeding by asserting that she is
not liable for the computational adjustment. However, petitioner
has already been held liable for such adjustment by virtue of the
dismissal of the partnership proceeding, which dismissal served
to sustain respondent's disallowance of the partnership items
relating to Computer Graphics for 1982. It follows that we may
not review petitioner's liability for the computational
adjustment in the present proceeding.
Viewing the matter from a slightly different perspective, it
is apparent that the provisions of section 6013(e) relieving a
spouse of liability in certain cases represent a defense to
liability. In the present case, petitioner's liability for tax
in respect of partnership items has already been determined.
Accordingly, we are without jurisdiction in an affected items
proceeding to reconsider petitioner's liability for such tax.
See Greene v. Commissioner, T.C. Memo. 1995-105 (period of
limitations for assessing a computational adjustment is a defense
to liability for such adjustment; such defense may therefore not
be asserted in an affected items proceeding); English v.
Commissioner, T.C. Memo. 1990-662 ("In a proceeding by an
individual partner based upon determinations of his tax liability
at the partner level, we have no power to deal with any question
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