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entry of decision under Rule 1551 pursuant to our opinion in
Blonien v. Commissioner, 118 T.C. 541 (2002). In that opinion,
we sustained respondent’s determination that petitioners had a
deficiency in 1992 Federal income tax as a result of the
allocation to Mr. Blonien (petitioner), in a partnership-level
proceeding under TEFRA,2 of a distributive share of cancellation
of debt (COD) income of the bankrupt law firm of Finley, Kumble,
Wagner, Heine, Underberg, Manley, Myerson & Casey (Finley
Kumble).
The remaining issues are: (1) Whether respondent used the
proper method to allocate COD income of Finley Kumble to
petitioner, and (2) whether proper adjustments to reduce
petitioner’s taxable income were omitted from respondent’s Rule
155 computations. We shall enter decision in accordance with
respondent’s computations.
Background
In Blonien v. Commissioner, supra, petitioners argued that
petitioner never became a partner of Finley Kumble, that the
period of limitations under section 6229 to assess a deficiency
1Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
year at issue.
2See the partnership unified audit and litigation procedures
enacted by the Tax Equity & Fiscal Responsibility Act of 1982
(TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648, codified at
secs. 6221 through 6233.
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