- 9 - proceeding. Id. at 550-552; GAF Corp. v. Commissioner, 114 T.C. 519 (2000); Maxwell v. Commissioner, 87 T.C. 783 (1986). Items determined at the partnership level include the amount of, and each partner’s distributive share of, partnership items of income. Dakotah Hills Offices Ltd. Pship. v. Commissioner, T.C. Memo. 1996-35; sec. 301.6231(a)(3)-1(a)(1), (4), Proced. & Admin. Regs. The amount of Finley Kumble’s COD income and each partner’s share of such COD income are partnership items. See sec. 301.6231(a)(3)-1(a)(1), Proced. & Admin. Regs. The first and second steps of respondent’s allocations to petitioner of his distributive share of COD income are items determined at the partnership level. The decision on the method of allocating partnership income is a partnership-level determination. The allocation and computation of COD income to petitioner under the two-step process must be and was determined at the partnership level because it affects the allocation of the remaining COD income to all the other partners. We do not have jurisdiction to review the method used to compute and allocate Finley Kumble COD income to petitioner. b. New Issue in a Rule 155 Proceeding Generally, new issues may not be raised in a Rule 155 proceeding. Rule 155(c); Harris v. Commissioner, 99 T.C. 121,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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