David E. and Jean H. Kohn - Page 11




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               Section 6213(a) provides that this Court may enjoin                    
          respondent's collection efforts if respondent is attempting to              
          collect amounts that have been placed in dispute in a timely                
          filed petition for redetermination.  See Powell v. Commissioner,            
          96 T.C. 707, 711 (1991).  However, this Court does not have                 
          jurisdiction in an affected items deficiency proceeding to                  
          restrain assessment and collection of computational adjustments             
          attributable to partnership items.  See id.   The amounts listed            
          as due in the notice of intent to levy represent the balance due            
          from petitioners for the deficiencies that were assessed by                 
          computational adjustment and section 6621(c) additional interest.           
          Having decided that we lack jurisdiction to redetermine these               
          items, we must deny petitioners' motion to restrain assessment              
          and collection.                                                             


                                                  An appropriate order                
                                             will be issued.                          

















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