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petitioners were partners. Currently, the case is before the
Court on respondent’s motion for summary judgment under Rule 121.
Petitioners responded to respondent’s motion under Rule 121(b).
We shall grant respondent’s motion for summary judgment.
Unless otherwise noted, section references are to the applicable
versions of the Internal Revenue Code. Rule references are to
the Tax Court Rules of Practice and Procedure.
Background
In 1996, petitioners were members of a partnership named RPT
PRN LLC. RPT PRN LLC was a limited liability company which was
classified as a partnership for income tax purposes.
On February 28, 1997, petitioners filed with respondent a
joint 1996 Federal income tax return. They reported $18,814 as
income received from RPT PRN LLC. The total tax due reported on
that tax return was $13,176. On October 4, 2000, respondent
issued to RPT PRN LLC a notice of final partnership
administrative adjustment (FPAA) for 1996. The FPAA determined
an increase in the income of RPT PRN LLC.
On January 18, 2000, a petition was filed with this Court on
behalf of RPT PRN LLC contesting the adjustments in the FPAA. By
order of the Court dated September 19, 2000, that proceeding was
dismissed for lack of jurisdiction.
On December 17, 2001, respondent issued to petitioners a
notice of deficiency for 1996. The notice determined that
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