Jeff Burger Productions - Page 2




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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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