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123 (1992); Gladstone v. Commissioner, T.C. Memo. 1992-10. That
is because, as relevant here, the record would have to be
reopened in order to permit petitioners to introduce the
spreadsheet into evidence to establish a discrepancy between
petitioners’ and respondent’s computations of petitioner’s Finley
Kumble COD income. See Harris v. Commissioner, supra at 124;
Cloes v. Commissioner, 79 T.C. 933, 937 (1982). Issues
considered in a Rule 155 proceeding are limited to “purely
mathematically generated computational items”. The Home Group,
Inc. v. Commissioner, 91 T.C. 265, 269 (1988), affd. on another
issue 875 F.2d 377 (2d Cir. 1989). Petitioners do not claim
there is a mathematical error or that the formula resulting from
application of the two-step process was improperly applied;
rather they argue the two-step process was not the proper method
to allocate COD income.
The notice of deficiency, notice of final partnership
administrative adjustment, and petitioner’s Schedule K-1 gave
petitioners notice of the amount of COD income allocated to
petitioner. Petitioners did not provide any reasons why they
failed to raise this issue prior to the Rule 155 computation. We
did not find or hold in our prior opinion that petitioner’s
.0170-percent profits or capital interest should or did determine
the amount of COD income that should be allocated to petitioner.
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