T.C. Memo. 2000-265
UNITED STATES TAX COURT
JACO L.C., JAY A. ODOM, TAX MATTERS PARTNER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18412-99. Filed August 21, 2000.
David D. Aughtry, for petitioner.
David R. MacKusick and Francis C. Mucciolo, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This matter is before the Court
on respondent’s Motion To Dismiss For Lack Of Jurisdiction And To
Strike with respect to refunds of overpayments to shareholders of
Jaco, L.C.
On September 30, 1999, respondent issued a notice of final
partnership administrative adjustment (FPAA) to the tax matters
partner for Jaco L.C., (the partnership), pertaining to the 1995
taxable year. Jaco L.C. is a limited liability corporation under
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