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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 deficiency notice. Sec. 6230(a)(1).
The second type of affected item requires a
partner level determination. N.C.F. Energy Partners v.
Commissioner, 89 T.C. 741, 744 (1987). Section
6230(a)(2)(A)(i) provides that the normal deficiency
procedures apply to those affected items which require
partner level determinations. The additions to tax for
negligence and valuation overstatement are affected
items requiring factual determinations at the
individual partner level. N.C.F. Energy Partners v.
Commissioner, supra at 745. It is well settled that we
lack jurisdiction to consider partnership items in an
affected items proceeding. Saso v. Commissioner, 93
T.C. 730 (1989).
Although petitioners allege error concerning affected items
(additions to tax), they are not pursuing the merits of that
controversy at this time. Instead, they ask us to redetermine
tax attributable to partnership items because they did not
receive notice of the settlement of those items.
In Crowell v. Commissioner, supra, we considered the effect
of a taxpayer’s lack of notice of the partnership proceeding on
the validity of an affected items notice of deficiency. In
Crowell, the taxpayers argued that they had not received notice
of the partnership-level proceeding from respondent in accordance
with section 6223(a), and no petition was filed to contest the
FPAA. We reasoned that the partnership items set forth in the
Crowell FPAA would become nonpartnership items under section
6223(e) if the taxpayers had not been sent proper notice. See
sec. 6231(b)(1)(D). We concluded that under these circumstances,
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