- 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.Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 Next
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