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final on May 24, 1994. See sec. 7481. On June 18, 1997,
petitioner filed a notice of election to participate in the
Hamilton partnership proceedings. On the same day, he filed a
motion for special leave to file a motion to reconsider or vacate
the Hamilton decision.
Upon completion of the partnership proceedings, respondent
made computational adjustments to petitioners' 1979 through 1985
tax liability. See secs. 6225, 6230(a)(1), 6231(a)(6). On
January 10, 1995, respondent issued separate statutory notices of
deficiency to petitioners that determined additions to tax for
the years 1979 through 1982 attributable to petitioner's
partnership interest in Hamilton. The additions to tax are for
overvaluation under section 6659 and negligence under section
6653(a)(1) and (2).
In their petition and motion to restrain assessment and
collection, petitioners not only contest the additions to tax,
but also contest the deficiencies that were assessed by
computational adjustment and the section 6621(c) interest.
Petitioners' claims are based upon the following assertions:
(1) Winer did not have authority to represent Hamilton; (2) the
extensions signed by Winer are invalid; (3) the petition filed by
Winer is invalid; (4) the period of limitations expired prior to
the mailing of the FPAA; (5) petitioners were denied due process
because of respondent's and Winer's actions during the TEFRA
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