-6-
“affected item”. As indicated above, the deficiency in
petitioners’ income tax for 1996 is attributable to partnership
items of RPT PRN LLC and was assessed as a computational
adjustment after the partnership-level proceeding involving that
entity was completed. Therefore, we lack jurisdiction to
redetermine that deficiency in this affected items case. Saso v.
Commissioner, supra; Palmer v. Commissioner, T.C. Memo. 1992-352;
Taylor v. Commissioner, T.C. Memo. 1992-219. Accordingly, we
hold that petitioners are precluded from contesting that
deficiency in this proceeding.
C. Accuracy-Related Penalty Under Section 6662(d)
Respondent determined that petitioners are liable for the
accuracy-related penalty under section 6662(d) as a result of a
substantial understatement of their income tax. Section 6662(a)
imposes an accuracy-related penalty in the amount of 20 percent
of the portion of the underpayment attributable to any
substantial understatement of income tax. Sec. 6662(b)(2). The
underpayment is defined as the amount by which any tax imposed
exceeds the excess of the sum of the amount shown as the tax by
the taxpayer on his return, plus amounts not so shown previously
assessed (or collected without assessment), over the amount of
rebates made. Sec. 6664(a). The understatement is defined as
the excess of the amount of tax required to be shown on the
return over the amount of tax shown on the return reduced by any
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