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docket No. 7982-00 (i.e., the partnership-level proceeding).
On June 3, 2002, the IRS sent a written notice to Mr.
Hudspath (June 3, 2002 notice) in which the IRS notified him,
inter alia, that there were certain adjustments set forth in the
respective SCC-FPAA and WIN-FPAA that the IRS made during the
examinations by the IRS of the respective taxable years 1996 and
1997 of SCC and WIN and that were the subject of the partnership-
level proceeding (the TEFRA case at docket No. 7982-00),5 which
affected petitioner’s taxable years 1996 and 1997. The June 3,
2002 notice indicated that, as a result of such adjustments,
there were flowthrough computational adjustments resulting in
increases in (1) petitioner’s income of $18,347 and $21,123 for
his taxable years 1996 and 1997, respectively, and (2) his
Federal income tax (tax) of $2,754 and $3,165 for such respective
years.
On or about June 25, 2002, the IRS assessed against peti-
tioner (1) additional tax of $2,754 and interest of $1,057.36 for
his taxable year 1996 and (2) additional tax of $3,165 and
interest of $954.60 for his taxable year 1997. Those assessments
were attributable to the flowthrough computational adjustments
resulting from the respective SCC-FPAA and WIN-FPAA that are
described in the preceding paragraph.
5On Apr. 2, 2001, the Court dismissed the partnership-level
proceeding for lack of jurisdiction.
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