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that the assessment of penalties relating to partnership
adjustments is not subject to deficiency procedures, and that the
deficiencies in income tax were paid and assessed prior to the
issuance of the notice of deficiency. See generally Kligfeld
Holdings v. Commissioner, 128 T.C. 192 (2007), and Notice 2000-
44, 2000-2 C.B. 255, for a general description of the transaction
in this case. Respondent determined in an affected items notice
the following deficiencies in and penalties on petitioners’
Federal income tax:
Penalty
Year Deficiency Sec. 6662(a)
1999 [2]$3,460,695 $1,399,552.80
2000 12,137 4,854.80
2 The deficiency in docket No. 12341-05 is $38,187
greater than the deficiency listed above because the
$38,187 was assessed as a computational adjustment. See
infra pp. 4-5.
The issues for decision are: (1) Whether petitioners have
previously paid a portion of the amount stated in the affected
items notice of deficiency, and (2) whether the Court lacks
jurisdiction over the section 6662(a) penalties determined in the
affected items notice.
1(...continued)
on a statutory notice of deficiency sent to John and Judith
Bedrosian. Docket No. 9664-07 is a partnership-level proceeding
concerning the validity of a final partnership administrative
adjustment notice.
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