- 4 - Goldman.4 The amendment to petition restates the position that Primco is not subject to the unified S corporation audit and litigation procedures. Petitioner subsequently filed a Motion to Dismiss for Lack of Jurisdiction consistent with the position outlined above. Respondent filed an objection to petitioner's motion to dismiss. This matter was called for hearing at the Court's motions session in Washington, D.C., on May 28, 1997. Counsel for the parties appeared at the hearing and presented argument with respect to petitioner's motion. Discussion The issue to be decided is whether the unified S corporation audit and litigation procedures contained in sections 6241-6245 apply to Primco, an S corporation whose sole shareholders during the years in issue were two grantor trusts. If we conclude that the unified procedures do not apply, then the FSAA issued to Primco is invalid, and we must dismiss this case for lack of jurisdiction. Subchapter D of chapter 63 of subtitle F was codified by section 4(a) of the Subchapter S Revision Act of 1982, Pub. L. 4 Notwithstanding the recitals in the amendment to petition, the Court ultimately changed the caption of this case to read "Primco Management Company, Alfred Dreyfus Goldman Revocable Living Trust, Alfred D. Goldman, Fiduciary, Tax Matters Person, Petitioner v. Commissioner of Internal Revenue, Respondent".Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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