Asa Investerings Partnership, Alliedsignal, Inc., Tax Matters Partner - Page 9




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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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