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Discussion
Petitioners argue that the long-term capital gain and
accuracy-related penalty determinations in the affected items
notice of deficiency are computational adjustments which section
6230(a) places outside the Court’s jurisdiction at the partner
level.9 Respondent argues that the Court has jurisdiction to
decide the issue concerning the long-term capital gain but not
the issue concerning the accuracy-related penalties. We agree
with respondent.
This Court is a court of limited jurisdiction, and we may
exercise our jurisdiction only to the extent provided by
9 In relevant part, sec. 6230(a) provides:
SEC. 6230(a). Coordination with Deficiency
Proceedings.--
(1) In general.--Except as provided in
paragraph (2) or (3), subchapter B of this
chapter shall not apply to the assessment or
collection of any computational adjustment.
(2) Deficiency proceedings to apply in
certain cases.--
(A) Subchapter B shall apply
to any deficiency attributable to--
(i) affected items
which require partner
level determinations
(other than penalties,
additions to tax, and
additional amounts that
relate to adjustments to
partnership items) * * *
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Last modified: November 10, 2007