- 14 - 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 computationalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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