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The first type of affected item is a computational
adjustment made to record the change in a partner's tax liability
resulting from the proper treatment of partnership items. Sec.
6231(a)(6); White v. Commissioner, supra. Once partnership level
proceedings are completed, respondent is permitted to assess a
computational adjustment against a partner without issuing a
notice of deficiency. Sec. 6230(a)(1); N.C.F. Energy Partners v.
Commissioner, 89 T.C. 741, 744 (1987); Maxwell v. Commissioner,
supra at 792 n.9. The computational adjustment that respondent
assessed against petitioner on August 29, 1994, was the
underpayment of income tax attributable to the disallowance of
petitioner's proportionate share of the loss claimed by Computer
Graphics on its partnership return.
The second type of affected item is one that depends on
factual determinations to be made at the partner level. N.C.F.
Energy Partners v. Commissioner, supra at 744. Section
6230(a)(2)(A)(i) provides that the normal deficiency procedures
apply to affected items that require determinations at the
partner level. The additions to tax for negligence and
substantial understatement of income tax are examples of such
affected items.
The Court may not adjudicate computational adjustments in an
affected items proceeding. Bradley v. Commissioner, 100 T.C.
367, 371 (1993); Saso v. Commissioner, 93 T.C. 730, 734 (1989);
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