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Partnership items are distinguished from affected items,
which are defined in section 6231(a)(5) as any item to the extent
such item is affected by a partnership item. See White v.
Commissioner, 95 T.C. 209, 211 (1990). The first type of
affected item gives rise to a computational adjustment without
the necessity of a partner-level proceeding. The computational
adjustment is made to record the change in a partner's tax
liability resulting from the proper treatment of partnership
items. See sec. 6231(a)(6); White v. Commissioner, supra. Once
partnership-level proceedings are completed, the Commissioner is
permitted to assess a computational adjustment against a partner
without issuing a notice of deficiency. See 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.
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 that require partner-
level determinations. Traditionally, additions to tax for
negligence were considered affected items requiring factual
determinations at the individual partner level. See N.C.F.
Energy Partners v. Commissioner, supra at 745; see sec.
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