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Background
For purposes of respondent’s motion, the parties do not
dispute the following factual allegations that are part of the
record. At all relevant times, Jeff Burger Productions, LLC
(Jeff Burger Productions), was a limited liability company that
is taxed as a partnership because it did not make an election to
be taxed as a corporation. Jeff Burger Productions filed part-
nership income tax returns, Forms 1065 (returns), for taxable
years 1994 and 1995. In those returns, it was indicated that
there were two partners/members of Jeff Burger Productions, i.e.,
Banana Moon Trust and Purple Passion Trust. Consequently, the
provisions of sections 6221 through 6234 apply.1
Respondent issued a Notice of Final Partnership Administra-
tive Adjustment which was addressed as follows:
JEFF BURGER
TAX MATTERS PARTNER
JEFF BURGER PRODUCTIONS LLC
40 EAST TONTO RIM DRIVE
SEDONA, AZ 86351-7880
J.C. Chisum (Mr. Chisum) timely mailed to the Court a
petition purportedly filed on behalf of Jeff Burger Productions.
Mr. Chisum identified himself in the petition as trustee of
Banana Moon Trust. Mr. Chisum further represented in the peti-
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011