Myron Barlow and Arlene Barlow - Page 41




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          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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