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introduced by respondent that the FPAAs were properly mailed in
these cases, and we so find. We find Josephine's and Catherine's
self-serving testimony on this matter to be vague and
insufficient to overcome respondent's evidence.
Having found that petitioners were properly notified of the
partnership proceeding, we lack jurisdiction to redetermine the
deficiencies on which the additions to tax in these cases are
based. Brookes v. Commissioner, 108 T.C. 1, 5 (1997), on appeal
(9th Cir., March 25, 1997). The deficiencies are attributable to
partnership items, properly considered solely in the partnership
proceeding. Saso v. Commissioner, 93 T.C. 730, 734 (1989);
Maxwell v. Commissioner, 87 T.C. 783, 788 (1986). Likewise,
petitioners' arguments that respondent failed to comply with the
applicable periods of limitation at the partnership level are
affirmative defenses that could have been raised in the
partnership level proceeding and may not be considered by the
Court at the partner level. Crowell v. Commissioner, supra at
693.
The second issue for decision is whether petitioners are
liable for the section 6653(a) additions to tax as determined by
respondent.
Section 6653(a)(1) provides for an addition to tax equal to
5 percent of the entire underpayment of tax if any part of the
underpayment is due to negligence or intentional disregard of
rules and regulations. Section 6653(a)(2) provides for an
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