Lawrence V. and Katharine T. Brookes - Page 1

                                     108 T.C. No. 1                                   

                               UNITED STATES TAX COURT                                

                LAWRENCE V. AND KATHARINE T. BROOKES, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11770-96.                  Filed January 2, 1997.           

                    Ps were partners in a partnership that was the                    
               subject of a partnership proceeding.  R mailed a notice                
               of final partnership administrative adjustment (FPAA)                  
               for taxable years 1983 and 1984 to the tax matters                     
               partner (TMP).  The TMP filed a petition, and Ps filed                 
               a motion to participate in the partnership proceeding,                 
               which this Court granted.  The TMP settled the                         
               partnership case and certified that no party objected                  
               to the settlement.  Ps did not receive notice of the                   
               settlement before the decision was entered by this                     
               Court but received notice of the decision 4 days after                 
               it was entered.  Ps object to the settlement and claim                 
               interests adverse to those of the TMP.  R assessed                     
               deficiencies in Ps' Federal income taxes for 1983 and                  
               1984 as "computational adjustments" based on the                       
               partnership adjustments.  See sec. 6231(a)(6), I.R.C.                  
               Thereafter, R mailed Ps a notice of deficiency for                     
               "affected items", determining additions to tax for 1980                
               and 1983.  Ps filed a petition for redetermination with                
               respect to the affected items deficiency and the 1983                  
               and 1984 assessments attributable to their share of                    
               partnership items.  R filed a motion to dismiss for                    
               lack of jurisdiction and to strike the portion of the                  

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