CGF Industries, Inc. and Subsidiaries - Page 47

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          supra, we sustain respondent's disallowance of petitioners'                 
          amortization deductions as determined in the notices of                     
          deficiency.21                                                               
               To reflect the foregoing and concessions by respondent,                
                                                  Decisions will be entered           
                                             under Rule 155.                          




























               21Given our holding herein, we offer no opinion on whether,            
          as respondent contends, amortizing term interests in partnerships           
          is inconsistent with the principles of subch. K.  We also need              
          not decide whether petitioners' argument based on the clear                 
          reflection of income principle, raised for the first time in                
          their opening brief, was made too late to be considered.  See               
          Aero Rental v. Commissioner, 64 T.C. 331, 338 (1975); Greenberg             
          v. Commissioner, 25 T.C. 534, 537 (1955).                                   

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