- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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