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determined in the notice of deficiency, but also the
computational adjustment assessed by respondent in respect of
petitioner's share of Computer Graphics' partnership items for
1982.
As previously indicated, respondent has filed a Motion to
Dismiss. In such motion, respondent moves to dismiss for lack of
jurisdiction, and to strike, such portion of the petition that
relates to adjustments "from or to" Computer Graphics for 1982.
In this regard, respondent contends that the Court's jurisdiction
in the present case is limited to redetermining the additions to
tax for 1982 as determined by respondent in the affected items
notice of deficiency.
Petitioner filed an objection to respondent's Motion to
Dismiss. In his objection, petitioner alleged: (1) He did not
receive an FPAA and was therefore not adequately notified of the
underlying partnership proceeding pursuant to section 6223(a);
(2) any FPAA mailed to him should be considered ineffective
because he had health problems rendering him unable to comprehend
such a notice; and (3) the additions to tax determined by
respondent must be assessed consistent with settlement agreements
previously offered by respondent to other partners of Computer
Graphics.
Respondent was directed to file a response to petitioner's
objections setting forth the basis upon which she relied to show
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