Opinion
14954-20
03-15-2024
MAPLE EQUESTRIAN, LLC, JEFFREY BLAND, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris, Judge.
On August 2, 2023, docket entry 25, petitioner filed a Motion to Substitute Parties and Change Caption, representing that the partnership has appointed a new tax matters partner, Verdant Property Management, LLC (Verdant), and that it therefore seeks to substitute Verdant as its tax matters partner in place of Jeffrey Bland in this case. The Motion indicates that respondent does not object to the relief sought.
On March 13, 2024, docket entry 30, petitioner filed with the Court a document titled First Supplemental Motion to Substitute Parties and Change Caption (Supplement to Motion). This document appears to be a supplement to petitioner's Motion to Substitute Parties and Change Caption, filed August 2, 2023, docket entry 25, and filed in accordance with the Court's Orders dated August 31, 2023, docket entry 27, and March 13, 2024, docket entry 29. The Court will recharacterize docket entry 30 as a supplement to petitioner's Motion.
Petitioner's Supplement to Motion, filed March 13, 2024, docket entry 30, indicates that Verdant is a member of Maple Equestrian, LLC (Maple); Maple's members appointed Verdant as the tax matters partner for tax year 2011; Verdant is eligible to serve as the tax matters partner for Maple pursuant to Treas. Reg. § 301.6231(a)(7)-2 because Verdant is a member-manager of Maple; and on February 20, 2024, Jeffrey Bland filed a statement with the Internal Revenue Service certifying Verdant as Maple's successor tax matters partner in accordance with the requirements of Treas. Reg. § 301.6231(a)(7)-(1)(d).
Unless otherwise indicated, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times.
After due consideration, it is
ORDERED that petitioner's First Supplemental Motion to Substitute Parties and Change Caption, filed March 13, 2024, docket entry 30, is recharacterized as "Supplement to Motion to Substitute Parties and Change Caption." It is further
ORDERED that petitioner's Motion to Substitute Parties and Change Caption, filed August 2, 2023, docket entry 25, as supplemented on March 13, 2024, docket entry 30, is granted in that Verdant Property Management, LLC, is substituted for Jeffrey Bland as the tax matters partner of Maple Equestrian, LLC. It is further
ORDERED that the caption of this case is amended to read: "Maple Equestrian, LLC, Verdant Property Management, LLC, Tax Matters Partner, Petitioner, v. Commissioner of Internal Revenue, Respondent."