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OPINION
THORNTON, Judge: This is an action for redetermination of
employment status pursuant to section 7436 and Rule 291.1
Petitioner, a limited liability company (LLC), is owned and
operated by Larry and Marilyn Conway (the Conways), who have
filed chapter 7 bankruptcy petitions. The question presently
before us is whether the automatic stay provision of 11 U.S.C.
section 362(a)(8) (2000) applies to these proceedings. As
discussed below, we conclude that it does not.
Background
Petitioner is a limited liability company, ostensibly
organized under Tennessee law. An LLC is a legal entity with
attributes of both a corporation and a partnership, although not
formally characterized as either one. Blakemore, “Limited
Liability Companies and the Bankruptcy Code: A Technical
Review”, 13 Am. Bankr. Inst. J. 12 (June 1994). Apparently, the
Conways are petitioner’s only members.
On June 13, 2005, petitioner filed its petition, signed by
Larry Conway “for” petitioner.2 The petition states, among other
1 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
2 Respondent has raised no issue as to whether Larry Conway
has authority to represent petitioner in this proceeding. In his
Rule 91(f) motion, filed Jan. 13, 2006, respondent identifies
Larry Conway as “petitioner’s principal”. On the record
presently before us, it appears that Larry Conway is authorized
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