- 5 - 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 taxPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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