Rodney J. Blonien and Noreen E. Blonien - Page 9

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          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,              






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