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determined to be the correct amount of such valuation or adjusted
basis (as the case may be). Sec. 6659(c). In the instant case,
respondent determined that the value claimed was more than 250
percent of the correct value, and therefore the applicable
percentage was 30.
In an affected items proceeding, res judicata precludes the
relitigation of any issue resolved in the partnership proceeding,
including the value or basis of partnership assets. N.C.F.
Energy Partners v. Commissioner, 89 T.C. 741, 747 (1987). As
stated, this Court has decided that the adjustments in the
related partnerships proceedings for 1984 are correct as to the
Alamo partnerships as set forth in the FPAA's. Thus the bases of
Alamo East Enterprises and Alamo East Enterprises 1984 are "0"
and "0", instead of $500,000 and $5,458,450, as claimed by the
respective partnerships for 1984. The respondent determined that
$12,846 was an amount attributable to a valuation overstatement
for 1984. On this record we find that petitioners did not meet
their burden to prove that respondent's determination was wrong.
Accordingly, we sustain respondent's determination as to 1984 on
this issue. For 1981, respondent's determination is the result
of an investment tax credit carryback from 1984 due to the
valuation overstatement. We therefore sustain the addition to
tax for the valuation overstatement for 1981.
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