Rodney J. Blonien and Noreen E. Blonien - Page 12

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               Having sustained respondent’s determinations and                       
          computations without having reached the merits of petitioners’              
          arguments and objections, we make some final observations.  We              
          make these observations to allay any impression--which                      
          petitioners have tried to create, in arguing their case and in              
          contesting respondent’s Rule 155 computations--that petitioner              
          has been treated unfairly in the TEFRA proceeding and in this               
          proceeding.                                                                 
               In making these observations, we do not intend to belittle             
          the economic insecurity and resulting aggravation and anxiety               
          that petitioner experienced in having been induced to join a law            
          firm that was about to go under.  But these are matters for which           
          the tax law provides no redress; we still would have sustained              
          respondent’s determination and adopted respondent’s computations,           
          even if we had been able to rule on the merits of petitioner’s              
          arguments and objections.                                                   
               In 1987, the year Finley Kumble announced its dissolution,             
          petitioner received cash distributions, in the form of                      
          partnership draws, that substantially exceeded his share of                 
          partnership profits.  As a result, petitioner had a negative                
          capital account at the end of 1987 that could only go more                  
          negative in the intervening years until 1992, the taxable year in           
          issue.  In that year, petitioner agreed with the Finley Kumble              
          bankruptcy trustee to make a $15,000 capital contribution with              






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