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petitioners contend that section 6230(a)(1) should not be read to
exempt from the deficiency procedures of subchapter B a
computational adjustment reflecting the treatment of partnership
items. Petitioners suggest that the term "tax liability" in the
definition of computational adjustment refers to the amount due
after respondent assesses a deficiency in accordance with
subchapter B.
Section 6225(a) restricts assessment of a deficiency
attributable to a partnership item until completion of the
partnership proceedings, while section 6230(a) makes subchapter B
procedures inapplicable to that assessment. Thus, contrary to
petitioners' argument, section 6201 assessment authority is not
limited to assessment under subchapter B procedures. The mere
reference to subchapter B in section 6201(d) does not mean that
respondent lacks assessment authority as to partnership items
unless respondent adheres to subchapter B procedures.
Petitioners argue that respondent must comply with section 6213,
which requires a notice of deficiency prior to assessment.
However, paragraph (3) of section 6213(h) refers to section
6230(a) for the applicability of the notice requirement to
deficiencies attributable to partnership items. In addition,
section 6216(4) provides: "For procedures relating to partnership
items, see subchapter C." Those references belie petitioners'
contention that respondent must comply with the deficiency
procedures of subchapter B before assessing a computational
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