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computational adjustments.10 We cannot redetermine deficiencies
under section 6226.11 See, e.g., Maxwell v. Commissioner, 87
T.C. 783, 787 (1986). Our prior decision in this case, ASA
Investerings Pship. v. Commissioner, T.C. Memo. 1998-305, was not
a decision which we made under the deficiency procedures. And,
deficiencies which are attributable to computational adjustments
are assessed under the general assessment authority of section
10Respondent claims that as a result of the partnership-
level proceeding, he has made certain computational adjustments
against petitioner. A computational adjustment is defined as
“the change in the tax liability of a partner which properly
reflects the treatment under this subchapter of a partnership
item.” Sec. 6231(a)(6). “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.” Sec. 301.6231(a)(6)-1T(b),
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6791 (Mar. 5,
1987). Our deficiency procedures generally do not apply to the
assessment or collection of a computational adjustment, sec.
6230(a)(1), and a notice of deficiency need not be issued, White
v. Commissioner, 95 T.C. 209, 211-212 (1990). However, under
sec. 6230(a)(2)(A)(i), our deficiency procedures do apply with
respect to any deficiency attributable to affected items which
require partner-level determinations.
11See sec. 6226(f), which provides:
SEC. 6226(f). Scope of Judicial Review.--A court
with which a petition is filed in accordance with this
section shall have jurisdiction to determine all
partnership items of the partnership for the
partnership taxable year to which the notice of final
partnership administrative adjustment relates, the
proper allocation of such items among the partners, and
the applicability of any penalty, addition to tax, or
additional amount which relates to an adjustment to a
partnership item.
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