Robert C. Olson - Page 5

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          but two of the participating partners (see Rule 247(b)) had                 
          entered into settlement agreements with respondent.  The final              
          order was served on petitioner at his Irish Lane address.                   
          Petitioner did not respond to the final order.                              
               On August 29, 1994, a computational adjustment was assessed            
          against petitioner.  The computational adjustment was made to               
          record the change in petitioner's tax liability resulting from              
          the Court's final order dismissing the partnership proceeding and           
          sustaining the partnership items relating to Computer Graphics              
          for 1982.  See sec. 6226(h).                                                
               The Affected Items Proceeding                                          
               On August 26, 1994, respondent mailed petitioner a notice of           
          deficiency in which she determined that, for 1982, petitioner was           
          liable for (1) additions to tax for negligence under sections               
          6653(a)(1) and 6653(a)(2), and (2) an addition to tax for a                 
          substantial understatement of income tax under section 6661.                
          These additions to tax are affected items because they are based            
          on tax owing by petitioner as a result of adjustments to                    
          partnership items appearing on Computer Graphics' partnership               
          return for 1982.  The affected items notice of deficiency was               
          mailed to petitioner at his Irish Lane address.                             
               Petitioner timely filed a petition for redetermination with            
          respect to the affected items notice of deficiency.  The petition           
          appears to place in dispute not only the additions to tax                   





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