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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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Last modified: May 25, 2011