129 T.C. No. 13 UNITED STATES TAX COURT PETER D. ADKISON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2532-06. Filed October 16, 2007. R sent to P a notice of deficiency for 1999. P filed a petition seeking to invoke the Court’s jurisdiction to redetermine the deficiency and to decide P’s claim for relief under sec. 6015(c), I.R.C. R moved to dismiss for lack of jurisdiction on the grounds (1) the notice of deficiency is invalid because the underlying adjustments constitute “partnership items” that are the subject of an ongoing partnership- level proceeding in Federal District Court, and (2) P’s claim for relief under sec. 6015(c), I.R.C., constitutes an “affected item” that can be reviewed only after the partnership-level proceeding is completed. The parties agree that the notice of deficiency is invalid because the underlying adjustments constitute “partnership items” that are the subject of an ongoing partnership-level proceeding in Federal District Court. P opposes dismissal of his claim under sec. 6015(c), I.R.C.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007