- 10 - if any shareholder in the corporation during that taxable year is a pass-through shareholder; i.e., a trust, nominee, or similar pass-through person. Because Primco's sole shareholders during the years in issue were two grantor trusts, we hold that Primco does not qualify under the small S corporation exception to the unified S corporation audit and litigation procedures, section 301.6241-1T(c)(2), Temporary Proced. & Admin. Regs., and, therefore, that the FSAA issued to Primco is valid. Consequently, we shall deny petitioner's Motion to Dismiss for Lack of Jurisdiction. To reflect the foregoing, An order will be issued denying petitioner's Motion to Dismiss for Lack of Jurisdiction.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011