- 41 -
See White v. Commissioner, 95 T.C. 209, 211 (1990). The first
type of affected item is a computational adjustment made to
record the change in a partner's tax liability resulting from the
proper treatment of a partnership item. Sec. 6231(a)(6); White
v. Commissioner, supra. Once partnership level proceedings are
completed, respondent is permitted to assess a computational
adjustment against a partner without issuing a notice of
deficiency. Sec. 6230(a)(1); N.C.F. Energy Partners v.
Commissioner, 89 T.C. 741, 744 (1987); Maxwell v. Commissioner,
supra at 792 n.9.15
The second type of affected item is one that is dependent on
factual determinations to be made at the individual partner
level. See N.C.F. Energy Partners v. Commissioner, supra at 744.
Section 6230(a)(2)(A)(i) provides that the normal deficiency
procedures apply to those affected items which require partner
level determinations. Additions to tax for negligence and for
valuation overstatement are affected items requiring factual
determinations at the individual partner level. See N.C.F.
Energy Partners v. Commissioner, supra at 744-745.
Additional interest under section 6621 is an affected item
15 See also sec. 301.6231(a)(6)-1T(b), Temporary Proced. &
Admin. Regs., 52 Fed. Reg. 6791 (Mar. 5, 1987), which provides
that “A computational adjustment includes any interest due with
respect to any underpayment or overpayment of tax attributable to
adjustments to reflect properly the treatment of partnership
items.”
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