Lawrence V. and Katharine T. Brookes - Page 14

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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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