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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 section
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