Michael V. Domulewicz and Mary Ann Domulewicz - Page 15




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          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.                                                                 





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