- 13 - this case would lead to the conclusion that examination of petitioners’ Schedule C was a separate examination. The record in this case supports the application of the additions to tax without regard to the burden of production. If the burden of production were on respondent, it would be satisfied in this case by the tax return, petitioner’s testimony, and other evidence in the record. Petitioners also ask that we reduce the amount of tax that was assessed after the partnership-level proceedings became final, which is not a part of the determination in the statutory notice in this case. That assessment was a computational adjustment that the Commissioner is permitted to assess against the partner without issuing a notice of deficiency. Secs. 6225, 6230(a)(1); N.C.F. Energy Partners v. Commissioner, 89 T.C. 741, 744 (1987); Maxwell v. Commissioner, 87 T.C. 783, 792 n.7 (1986). We have no jurisdiction in this case over that computational adjustment. For purposes of the additions to tax, however, we are satisfied by the evidence in this case that the correct amount of the underpayment is less than the amount assessed and that the correct amount should be used in computing the additions to tax. That amount will be computed by determining the tax based on disallowance of the sum of $13,150. Finally, petitioners assert that the investment in Cal-Neva was not a “tax-motivated transaction” for purposes of sectionPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: March 27, 2008