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Rule 155 Computation
Respondent stated on brief: “If respondent prevails, this
case may require a Rule 155 computation.” We agree that a Rule
155 computation is appropriate. Respondent did not allow
petitioners credit for the $2,000 of Finley Kumble COD income
that they reported on their 1992 return. Respondent also
indicated on brief that Exhibit 10-J may have a bearing on the
appropriate adjustments if a Rule 155 computation is required;
other items and amounts determined at the partnership level to be
allocated to Mr. Blonien are not clearly set forth in the FPAA
and the deficiency notice. The parties should address and
resolve these issues in the Rule 155 computation.
To reflect our holdings herein,
Decision will be entered
under Rule 155.
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