- 12 - 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 withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011