- 15 - limitations for assessment of the taxpayer’s income tax, even when the petition is not authorized or ratified by the taxpayer), affg. T.C. Memo. 2003-288, supplemented by T.C. Memo. 2004-14. This suspension continues for the period during which a proceeding may be brought in this Court, for the pendency of any proceeding actually brought, and for 1 year thereafter. See sec. 6229(d). After a final partnership-level adjustment has been made to a partnership item in a unified partnership proceeding, a corresponding “computational adjustment” must be made to the tax liability of a partner. See sec. 6231(a)(6) (defining “computational adjustment” as “the change in the tax liability of a partner which properly reflects the treatment under this subchapter of a partnership item”, and providing that “All adjustments required to apply the results of a proceeding with respect to a partnership under this subchapter to an indirect partner shall be treated as computational adjustments.”); see also sec. 6230(c)(1)(A)(ii).11 A computational adjustment may then affect the amounts of other items on a partner’s return. Where an increase in a partner’s tax liability is attributable to an “affected item” that flows strictly from a computational adjustment, no notice of deficiency need be sent to the partner, 11 The parties agree that the deficiency determined in the affected items notice of deficiency is a computational adjustment.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: November 10, 2007