-2-
section 62231 to the Tax Matters Partner (TMP) of In Touch
Properties, LLC (In Touch), a limited liability company
classified as a partnership for Federal income tax purposes.2 In
the FPAA, respondent disallowed deductions claimed by In Touch
for professional fees, marketing expenses, consulting fees, and
amortized startup expenditures; determined that the members’ at-
risk amount under section 465 must be reduced by $176,818;
determined that the total capital contributed to In Touch as of
December 31, 2000, was $50,000; and determined that a
computational adjustment to net earnings (loss) from self-
employment must be made. A petition for a readjustment of
partnership items was filed on behalf of In Touch. Because the
petition did not identify a TMP or reflect that it was filed by
the TMP, we ordered In Touch to identify its TMP. On June 13,
2005, we received and filed a Notice of Identification of Tax
Matters Partner, which identified David England as the TMP. We
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2 Although In Touch had fewer than 10 members during 2000,
it did not meet the definition of a small partnership under sec.
6231(a)(1)(B) because one of its members was a passthrough
entity. See sec. 6231(a)(1)(B)(i); sec. 301.6231(a)(1)-1(a)(2),
Proced. & Admin. Regs. Consequently, In Touch is an entity
subject to the partnership audit and litigation procedures of
secs. 6221-6231.
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