- 8 - $7,482.17 (Finley Kumble’s total COD income of $55,777,452, multiplied by petitioner’s 0.0170-percent interest in Finley Kumble’s profits and losses, minus the $2,000 credit for the COD income actually reported by petitioners on their return). Respondent argues the Court lacks jurisdiction to review the allocation of COD income to petitioner because such allocation is a partnership item that could only have been raised in the prior TEFRA proceeding. Respondent also argues petitioners are raising new issues in the Rule 155 computation. We hold, pursuant to our opinion in Blonien v. Commissioner, 118 T.C. 541 (2002), that the Court does not have jurisdiction to consider the proper methodology to allocate Finley Kumble COD income to petitioner because such allocation is a partnership- level item that was determined in the partnership-level TEFRA proceeding. Moreover, petitioners’ objection to respondent’s computation is an attempt to raise a new issue we would not address at this stage of the proceedings even if we did have jurisdiction. a. Jurisdiction To Review Method Used To Compute and Allocate COD Income We agree with respondent that we have no jurisdiction to consider the allocation of COD income to petitioner because such allocation is a partnership item. We have no jurisdiction to consider partnership items in a partnership-level deficiencyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011