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If a computational adjustment results in a
deficiency in a partner's tax, the partner is accorded
the right to challenge the adjustment pursuant to the
deficiency procedures provided for in subtitle F,
chapter 63, subchapter B of the Internal Revenue Code
only if and to the extent the change in the partner's
tax liability cannot be made without making one or more
partner-level determinations. See sec. 6230(a)(1);
sec. 301.6231(a)(6)-1T, Temporary Proced. & Admin.
Regs., 52 Fed. Reg. 6790 (Mar. 5, 1987).
Therefore, we have jurisdiction in this proceeding to determine
the effect of the Finley Kumble partnership-level allocations on
petitioners’ tax liability to the extent the change in
petitioners’ tax liability resulting from the partnership-level
allocations requires partner-level determinations.
Determining whether the assessment of the deficiency is
timely under the applicable statute of limitations requires a
partner-level determination of the timeliness of respondent’s
assessment with respect to each partner in the partnership.
Similarly, determining whether respondent gave petitioners credit
for the income recognized on their return in computing their
deficiency and determining the effect of the additional Finley
Kumble income on the phaseout of itemized deductions under
section 68(a)10 may require partner-level determinations. We
10Because the phaseout of itemized deductions under sec.
68(a) is computational and does not require any special partner-
level factual determinations, it appears that respondent could
have assessed the affected item adjustment as computational
without following the deficiency procedures of ch. 63, subch. B
of the Internal Revenue Code. See sec. 301.6231(a)(6)-1T(a),
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 6790 (Mar. 5,
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