MR. TUCKER: Thank you, Your Honor. I'd like to thank the Court for the opportunity to say a few remarks about Judge Scott. The Tax Court, private bar, Chief Counsel's Office, and her numerous friends and family have suffered a tremendous loss with her passing. All parties looked forward to having Judge Scott preside at calendars. Since Judge Scott was from Alabama, she enjoyed presiding over numerous calendars in the Southeast. My experience with Judge Scott goes back to 1970. She was the presiding Judge at my first Tax Court trial. The case involved a hobby loss of a petitioner who ran a dog kennel. The petitioner was pro se. I asked what I thought were the right questions to set forth the facts for the record. When I was finished, Judge Scott asked only a couple of questions, but they cut right to the heart of the case. I can say I always learned something about Tax Court practice from every Judge Scott calendar that I attended. The tax bar, and the legal profession in general, have long recognized Judge Scott's excellence. A portion of the law school at the University of Alabama is named for her. Your Honor, the Chief Counsel's Office would like to join the Tax Court in expressing our sorrow over the passing of Judge Scott. JUDGE WELLS: Thank you, Mr. Tucker. Very appropriate words, indeed. We are all very saddened by our loss of our colleague, and we appreciate your remarks. And we thank you for attending this ceremony, and that concludes this ceremony. And we will now take a recess. Thank you. REPORTS OF THE UNITED STATES TAX COURT LAWRENCE V. AND KATHERINE T. BROOKES, Docket No. 11770-96. Filed January 2, 1997. Ps were partners in a partnership that was the subject of a partnership proceeding. R mailed a notice of final partnership administrative adjustment (FPAA) for taxable years 1983 and 1984 to the tax matters partner (TMP). The TMP filed a petition, and Ps filed a motion to participate in the partnership proceeding, which this Court granted. The TMP settled the partnership case and certified that no party objected to the settlement. Ps did not receive notice of the settlement before the decision was entered by this Court but received notice of the decision 4 days after it was entered. Ps object to the settlement and claim interests adverse to those of the TMP. R assessed deficiencies in Ps' Federal income taxes for 1983 and 1984 as "computational adjustments" based on the partnership adjustments. See sec. 6231(a)(6), I.R.C. Thereafter, R mailed Ps a notice of deficiency for "affected items", determining additions to tax for 1980 and 1983. Ps filed a petition for redetermination with respect to the affected items deficiency and the 1983 and 1984 assessments attributable to their share of partnership items. R filed a motion to dismiss for lack of jurisdiction and to strike the portion of the petition that attempts to put the 1983 and 1984 assessments into issue. Ps argue they were denied due process in the partnership proceeding because they did not have an opportunity to be heard and did not have the right to appeal from a stipulated decision. Ps filed a cross-motion to dismiss for lack of jurisdiction because R did not issue a notice of deficiency for |