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jurisdiction over partnership items in an affected items
proceeding. However, petitioner contends that, for purposes of
computing the additions to tax for negligence and substantial
understatement of income tax, the underpayment amount (i.e., the
amount of the computational adjustment assessed on August 29,
1994) should be less than the amount reflected in the affected
items notice of deficiency.3
Specifically, petitioner alleges that he did not receive
notice of settlement agreements between respondent and other
partners of Computer Graphics in which respondent allegedly
reduced the amount of the underpayment with respect to which
additions to tax are calculated. From this, petitioner concludes
that he should be entitled to reduce the amount of the
underpayment as stated in the affected items notice of deficiency
for purposes of calculating the additions to tax determined in
such notice.
Respondent contends that this Court lacks jurisdiction to
reduce the amount of the underpayment; i.e., the computational
adjustment, in an affected items proceeding. We agree with
respondent.
3 The additions to tax for negligence under sec. 6653(a)(1)
and (2), as well as the addition to tax for substantial
understatement of income tax under sec. 6661, are predicated on
an underpayment of tax. In other words, the amount of such
additions is directly related to the amount of an underpayment of
tax.
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