Rodney J. Blonien and Noreen E. Blonien - Page 6

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          income among the partners in proportion to their contributions to           
          the partnership under the bankruptcy plan.  The total                       
          contribution by all partners was $38,962,594.  Petitioner’s                 
          second COD income allocation of $10,233 was calculated by                   
          dividing his $15,000 contribution by the total of all partner               
          contributions, $38,962,594, and then multiplying the result by              
          the remaining COD income, $26,580,484 (15,000/38,962,594 = .03849           
          percent x $26,580,484).4                                                    
               In order to explain fully the two-step process, respondent             
          attached to his response to petitioners’ objection to his                   
          computation a spreadsheet titled “IRS Closing Agreement” that               
          reflects the computation of the COD income allocation to                    
          petitioner using the two-step process described above.  Neither             
          party introduced the closing agreement or the spreadsheet into              
          evidence during the trial of the case.                                      
               The following adjustments (the adjustment items) to                    
          petitioners’ income listed on respondent’s Form 4549A-CG, Income            
          Tax Examination Changes, reduce petitioners’ taxable income by              
          $1,199:  (1) Capital loss of $18, (2) Finley Kumble interest                



               4The computation shows the second allocation amount is                 
          $10,231, which is $2 less than the $10,233 allocation claimed by            
          respondent.  The discrepancy could be caused by mistakes in                 
          amounts recited in respondent’s response.  This computational               
          discrepancy is minimal and harmless and does not change our                 
          decision.                                                                   





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