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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, Scenic Wonders Gallery, LLC
(Scenic Wonders) was a limited liability company that is taxed as
a partnership because it did not make an election to be taxed as
a corporation. Scenic Wonders filed partnership income tax
returns, Forms 1065 (returns), for taxable years 1995 and 1996.
In those returns, it was indicated that there were two part-
ners/members of Scenic Wonders, i.e., Photo Art Publishing Trust
and Photo Art Marketing Ent. 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:
TAX MATTERS PARTNER
SCENIC WONDERS GALLERY LLC
PHOTO ART MARKETING ENTERPRISES
320 N 89A 14
SEDONA, AZ 86336
John P. Wilde (Mr. Wilde) timely mailed to the Court a
petition purportedly filed on behalf of Scenic Wonders. Mr.
Wilde identified himself in the petition as co-trustee of Photo
Art Marketing Trust. Mr. Wilde further represented in the
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