- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011