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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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Last modified: November 10, 2007