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On June 3, 2002, respondent sent petitioner a notice of
computational adjustment relating to partnership items. That
notice set forth net income adjustments of $18,347 and $21,123 to
petitioner’s 1996 and 1997 taxable years, respectively.
By notice of deficiency dated June 21, 2002, respondent
determined deficiencies of $2,739 and $4,044 relating to 1996 and
1997, respectively, and a $955 section 6662(a) accuracy-related
penalty relating to 1996. On June 24, 2002, respondent assessed
a computational adjustment against petitioner resulting from
adjustments of the partnership items. On September 16, 2002,
petitioner, while residing in Stephens City, Virginia, filed his
petition with this Court.
OPINION
Petitioner contends that respondent’s determinations
relating to this affected items proceeding should not be
sustained because respondent informed petitioner that, pursuant
to the April 24, 2002, stipulation, petitioner would have an
opportunity to challenge the partnership items. In support of
his contention, petitioner, who is blind, asserts that he
justifiably relied on respondent to explain the terms of the
stipulation.
Petitioner’s credible testimony and the plain language of
the stipulation (i.e., “The tax treatment of petitioner’s
partnership items * * * will be resolved in a separate
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