- 2 -
Temporary Proced. & Admin. Regs., 52 Fed. Reg. 3003 (Jan. 30,
1987), that is excluded from the unified S corporation audit and
litigation procedures prescribed by sections 6241 through 6245.1
Background
On March 26, 1996, respondent issued a Notice of Final S
Corporation Administrative Adjustment (FSAA) to the tax matters
person (TMP) of Primco Management Company (Primco) determining
adjustments to Primco's tax returns for 1990, 1991, and 1992. On
June 24, 1996, Julian P. Kornfeld, Esq., filed a petition for
readjustment on behalf of Primco contesting the above-described
notice. The petition includes allegations that Primco is a small
S corporation that is not subject to the unified S corporation
audit and litigation procedures.
Respondent filed an answer to the petition denying the
allegation that Primco is not subject to the unified S
corporation audit and litigation procedures. In particular,
respondent alleges that, during the years in issue, Primco's sole
shareholders were the Alfred Dreyfus Goldman Revocable Living
Trust and the Monty H. Goldman Revocable Living Trust
(collectively referred to hereinafter as the trusts). Respondent
further contends that the trusts are not "natural persons" within
the meaning of section 301.6241-1T(c)(2), Temporary Proced. &
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011