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(1984). Pursuant to section 6213(a),4 this Court’s jurisdiction
to redetermine a deficiency in tax depends upon a valid notice of
deficiency and a timely filed petition. See Savage v.
Commissioner, 112 T.C. 46, 48 (1999). Section 6212(a) provides:
“If the Secretary determines that there is a deficiency in
respect of * * * [among other taxes, the income tax], he is
authorized to send notice of such deficiency to the taxpayer”.
Section 6213 authorizes a taxpayer to whom a notice of deficiency
has been sent to petition the Tax Court for a redetermination of
such deficiency.
In response to the notice, petitioner filed the petition on
December 9, 1997. Prima facie, we have jurisdiction to
redetermine the deficiencies determined in the notice. See,
generally, secs. 6211 through 6214. Petitioner argues, however,
that the determinations in the notice involve either partnership
items that cannot be adjudicated in a partner-level proceeding,
see sec. 6221, or affected items that cannot be determined before
final resolution and adjustment of the partnership items to which
they relate. Therefore, petitioner argues that the notice is
invalid, citing N.C.F. Energy Partners v. Commissioner, 89 T.C.
4Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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