Opinion
20178-18 20179-18
08-04-2023
PATRICIA MARCELLO ANDERSON, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
James S. Halpern Judge
Respondent has determined deficiencies in petitioners' federal income taxes for their taxable years 2010 through 2013 and 2015. Respondent's adjustments to petitioners' income for the years at issue include increases in their income for those years attributable to deposits into bank accounts in the names of various limited liability companies that may be owned indirectly by petitioners through a business structure terminating in partnership whose members are two personal trusts. The Court has inquired informally of the parties whether the purported business structure terminating in a partnership and two trusts deprives us of jurisdiction to redetermine deficiencies in tax with respect to what might be partnership items or items of one or more trusts. See, e.g., I.R.C. sec. 6221 (tax treatment of partnership items determined at partnership level). Respondent wishes to address our inquiry in a memorandum of law. In light thereof, it is
ORDERED that respondent shall file a memorandum of law addressing our inquiry no later than August 18, 2023. It is further
ORDERED that petitioners may, but are not required to, respond no later than September 1, 2023.