- 51 -
See Solowiejczyk v. Commissioner, 85 T.C. 552 (1985), affd.
without published opinion 795 F.2d 1005 (2d Cir. 1986); Barlow
v. Commissioner, T.C. Memo. 2000-339.
Petitioner contends that he should not be held liable for
the increased interest rate under section 6621(c) because he
invested in Madison with the intent to earn a profit.
Respondent contends that we lack jurisdiction to determine
whether petitioner is liable for the increased interest rate,
citing our Opinion in White v. Commissioner, 95 T.C. 209 (1990).
We agree with respondent. As explained below, we lack both
affected item jurisdiction under section 6230 and section
6621(c)(4) jurisdiction to determine whether petitioner is
liable for additional interest under section 6621(c). See White
v. Commissioner, supra.
1. Affected Item Jurisdiction
An affected item is any “item to the extent such item is
affected by a partnership item.” Sec. 6231(a)(5). Affected
items are of two types. The first type is a computational
adjustment made to reflect a change in a partner’s tax liability
resulting from partnership-level adjustments. Sec. 6231(a)(6);
N.C.F. Energy Partners v. Commissioner, 89 T.C. at 744. The
Commissioner may assess a computational adjustment against a
partner without issuing a notice of deficiency once the
partnership proceeding is completed. Sec. 6230(a)(1); N.C.F.
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