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have jurisdiction in this proceeding to review these partner-
level determinations. Before considering the merits of
petitioners’ claims, we consider petitioners’ evidentiary
objections.
Petitioners’ Evidentiary Objections
Petitioners object to the admissibility of Exhibit 3-J
(Finley Kumble’s partnership return for 1992) and Exhibit 4-J
(Finley Kumble Schedule K-1 for Mr. Blonien for 1992) on the
ground that respondent failed to authenticate the documents under
rule 901 of the Federal Rules of Evidence and on the ground that
the documents are inadmissible hearsay under rule 802 of the
Federal Rules of Evidence.
Respondent submitted a certification that the partnership
return is an authentic copy of the document filed with respondent
by Finley Kumble. The copy of the document is incomplete because
it does not include the Schedules K-1 for all 280 partners.
Petitioners argue that the entire document is inadmissible
because the copy is incomplete.
10(...continued)
1987). On the other hand, in certain circumstances, the
computational adjustment for passed-through discharge of
indebtedness income could require a partner-level solvency
determination. See sec. 108(a)(1)(B), (d)(6). In the case at
hand, respondent followed the deficiency procedures of ch. 63,
subch. B, of the Internal Revenue Code in connection with both
the affected item and the computational adjustment.
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