- 11 - 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) * * *Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: November 10, 2007