Rodney J. Blonien and Noreen E. Blonien - Page 14

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          account to go negative.  The determinations in the partnership-             
          level TEFRA proceeding--to which we are bound to give effect--              
          have resulted in the recapture of those tax benefits and also               
          take into account the current economic benefit petitioner                   
          realized as a partner in 1992 from the discharge of his share of            
          the remaining liability to the firm’s creditors.  What goes                 
          around comes around.                                                        
              To reflect the foregoing,                                              
                                            Decision will be entered                  
                                        in accordance with respondent’s               
                                        computations.                                 



























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