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and 1984 under section 6653(a)(1) in the amounts of $1,159.70 and
$43.65, respectively. Respondent also determined for both years
additions to taxes under section 6653(a)(2) in the amounts of 50
percent of the interest due on the portion of the underpayments
of taxes attributable to negligence.
Certain issues raised in this case by petitioners' Motion to
Restrain Collection and respondent's Motion to Dismiss for Lack
of Jurisdiction and to Strike the Claims Relating to the
Deficiency Attributable to Partnership Items and Increased
Interest Pursuant to I.R.C. Section 6621(c) were decided by the
Court in Greene v. Commissioner, T.C. Memo. 1995-105 (Greene I).
By an amendment to petition, petitioners attempted to put at
issue the period of limitations for the "deficiencies being
assessed". The Court found that the affected items deficiency
notices here involved were mailed to petitioners within 1 year of
the date of entry of decision in the partnership level
proceedings in docket No. 5757-92. See sec. 6229(d). The Court
also found that petitioners were not entitled to direct notice of
the partnership level proceedings and that any reliance on
Crowell v. Commissioner, 102 T.C. 683 (1994), is misplaced.
On brief petitioners state that they "believe that the Court
has already ruled on the statute of limitations issue" in
Greene I. We agree, and we decline to revisit the issue. See,
e.g., Crocker v. Piedmont Aviation, Inc., 49 F.3d 735, 739 (D.C.
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