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          partner in Finley Kumble, and that the appropriate way to collect           
          additional amounts that might be owed by the Finley Kumble                  
          partners was to determine the partnership items in a partnership-           
          level proceeding.  See sec. 6221 (“the tax treatment of any                 
          partnership item * * * shall be determined at the partnership               
          level” (Emphasis added.)).  Had petitioners properly notified               
          respondent at the time they filed their 1992 return of their                
          position that Mr. Blonien was not a partner in Finley Kumble,               
          respondent could have converted the issue to a partner-level item           
          under section 6231(b)(1)(A) or could have addressed the issue, on           
          notice to petitioners, in a partnership-level proceeding under              
          section 301.6222(b)-2T(a), Temporary Proced. & Admin. Regs.,                
          supra, all within the period of limitations.  By failing to file            
          a Form 8082 after receiving a Schedule K-1 from Finley Kumble,              
          petitioners accepted the position stated on the Schedule K-1 Mr.            
          Blonien received (that Mr. Blonien was a partner in Finley                  
          Kumble), deprived respondent of an opportunity to address the               
          issue before the expiration of the period of limitations, and               
          thereby waived the right to take an inconsistent position on                
          their return.                                                               
               It was petitioners’ conduct in claiming on prior returns               
          that Mr. Blonien was a partner, and in failing to notify                    
          respondent timely of their position that Mr. Blonien was not a              
          partner, that deprived Mr. Blonien of the opportunity to have the           
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