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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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