- 33 - that he agreed to be treated as a partner of Finley Kumble, at least for certain purposes. However, because we lack jurisdiction to consider petitioners’ contention that Mr. Blonien was not a partner in Finley Kumble, the document is not relevant to the resolution of any issue in dispute in this case. Finally, petitioners argue that Exhibit 17-J, a letter from petitioners’ accountant to respondent, should not be admitted. In the letter, petitioners’ accountant requested an abatement of late-filing penalties. In support of the request, petitioners’ accountant stated that abatement is appropriate because Mr. Blonien was a partner in Finley Kumble, and Finley Kumble had not provided information to petitioners in time to enable them to timely file their Federal income tax returns. Petitioners argue that these statements were not excepted from hearsay by rule 801(d)(2)(C) of the Federal Rules of Evidence (statements by authorized agents of a party) because respondent failed to show that the accountant was authorized by petitioners to make the statements. We need not consider these issues because the letter is irrelevant to any issue in dispute in this case. We have no jurisdiction to consider petitioners’ argument that Mr. Blonien was not a partner in Finley Kumble. Therefore the letter will not be admitted in evidence.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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