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petitioners, pursuant to the authority provided under section
6229(b)(1)(A), also extended the time for making adjustments at
the partnership level, but only with respect to petitioners'
partnership items (or affected items) for taxable year 1982.
The respective Consents executed by petitioners were
executed prior to the expiration of the section 6229(a) period of
limitations on assessment for 1982, as extended by Jacobson for
all partners, and such Consents were sufficient to satisfy
section 6229(b)(2). See Foam Recycling Associates v.
Commissioner, supra. We hold that the period of limitations for
assessment of tax related to petitioners' former partnership
items (or affected items) for 1982 under section 6229(a) had not
yet expired when respondent issued the notices of deficiency for
docket Nos. 21209-90, 22399-90, and 22466-90. Respondent is
sustained on this issue.
B. Section 6653(a)--Negligence
In notices of deficiency for 1981 and 1982, respondent
determined that each of petitioners was liable for the additions
to tax for negligence under section 6653(a)(1) and (2).
Petitioners have the burden of proving that respondent's
determinations of these additions to tax are erroneous. Rule
142(a); Luman v. Commissioner, 79 T.C. 846, 860-861 (1982).
Section 6653(a)(1) imposes an addition to tax equal to 5
percent of the underpayment if any part of an underpayment of tax
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