BLONIEN v. COMMISSIONER

Docket No. 2660-00.

118 T.C. 541 (2002)

118 T.C. No. 34

RODNEY J. BLONIEN AND NOREEN E. BLONIEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 12, 2002.


Attorney(s) appearing for the Case

R. Todd Luoma, for petitioners.

Kathryn K. Vetter, for respondent.


BEGHE, Judge:

On December 17, 1999, respondent issued petitioners an "affected items" notice of deficiency of $11,826 in their 1992 Federal income tax. The deficiency is attributable to inclusion in the income of petitioner Rodney J. Blonien (Mr. Blonien) of his distributive share of cancellation of debt (COD) income of Finley, Kumble, Wagner, Heine, Underberg, Manley, Myerson & Casey (Finley Kumble), a law partnership that had become insolvent.

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