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2, Ltd. v. Commissioner, T.C. Memo. 1996-515. The parties
stipulated all issues except whether the partnership items were
allocated to the partners in accordance with a settlement
agreement dated May 20, 1993, between Hoyt and respondent’s
Sacramento, California, Appeals Office. Id. The Court
determined that respondent’s allocation method was appropriate
and entered an order and decision in each docket number. Id.
Each order and decision reflected the determination of various
partnership items and stated in pertinent part:
That the additions to tax under I.R.C. ��6653(a)(1),
6653(a)(2), 6659, and 6661, and the additional interest
under I.R.C. �6621(c), formerly �6621(d), which were
all mentioned in the Notice of Final Partnership
Administrative Adjustment * * * are affected items as
defined in I.R.C. �6231(a)(5) that require factual
determinations to be made at the partner level, and are
not within the Court’s jurisdiction in this case.
On March 12, 1998, respondent sent petitioner a Form 4549A-
CG, Income Tax Examination Changes, reflecting changes made for
petitioner’s 1982 through 1988 tax years resulting from the
orders and decisions entered pursuant to Shorthorn Genetic Engg.
Respondent determined deficiencies in petitioner’s income tax of
$11,556, $5,059, $7,367, $6,856, $6,106, $2,914, and $312,
respectively. Respondent did not assert any penalties or
additions to tax but determined that petitioner was liable for
additional interest on tax-motivated transactions under section
6621(c) (section 6621(c) interest). Because no penalties or
additions to tax were asserted, and because respondent assessed
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