-5-
section 62253 because of the partnership-level proceeding (i.e.,
the TEFRA case at docket No. 7982-00). The Commissioner specifi-
cally reserved in respondent’s motion the right to proceed under
sections 6221 through 6233 in order to deal with flowthrough
computational adjustments resulting from the respective SCC-FPAA
and WIN-FPAA and to issue any affected items notice of defi-
ciency.
On April 19, 2002, Mr. Hudspath signed, and on April 24,
2002, the Commissioner’s counsel signed, a stipulated decision
document and a stipulation (parties’ stipulation) in petitioner’s
non-TEFRA case at docket No. 7901-00, which they submitted to the
Court. On April 26, 2002, pursuant to the stipulation of the
parties, the Court entered a decision in petitioner’s non-TEFRA
case at docket No. 7901-00, which stated, inter alia, that there
were overpayments of $716 and $709 for Mr. Hudspath’s taxable
years 1996 and 1997, respectively,4 and that he was not liable
for either 1996 or 1997 for the accuracy-related penalty under
section 6662(a). The parties’ stipulation in petitioner’s non-
TEFRA case at docket No. 7901-00 provided:
1. Petitioner reported certain items on his 1996
and 1997 income tax returns related on his investment
3All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
4The overpayments were the result of increased deductions
for interest expenses paid by Mr. Hudspath on behalf of SCC in
1996 and 1997.
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