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$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 deficiency
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