T.C. Memo. 2006-67
UNITED STATES TAX COURT
SUE TAYLOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21744-03. Filed April 6, 2006.
P filed Federal income tax returns for P and two
LLCs for 1999 and 2000. R subsequently determined
deficiencies and penalties with respect to P’s income
taxes, which P contested primarily on the basis of tax
protester arguments. P also argued that R did not
provide to either of the LLCs a final partnership
administrative adjustment and therefore the deficiency
notice mailed to her was premature.
Held: Following a concession by R, P is liable
for the remaining deficiencies, except for an
adjustment for a reduced share of income from one LLC
in 1999, determined by R for 1999 and 2000 including
self-employment taxes pursuant to sec. 1401, I.R.C.
Held, further, P is liable for a penalty under
sec. 6662, I.R.C., for 1999 and 2000.
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