Opinion
10837-21
12-17-2021
East Fork Investment Group, LLC, Monteagle-East Fork Fund, LLC, A Partner Other Than the Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On June 10, 2021, petitioner filed the petition in this case. Petitioner states in the petition that petitioner is the tax matters partner, but notes that petition is filed during the section 6226(b)(1) petition period.
Under Rule 214(d), Tax Court Rules of Practice and Procedure, if a petition is filed by the tax matters partner, the case is to be captioned, for example, "ABC Partnership, Mary Doe, Tax Matters Partner, Petitioner". This remains true regardless of whether the petition is filed during the section 6226(a) or the section 6226(b)(1) petition period. In other words, if the petitioner is the TMP, then the caption must so indicate, regardless of the period during which the petition was filed.
Upon due consideration, it is
ORDERED that the caption of this case is amended to read "East Fork Investment Group, LLC, Monteagle-East Fork Fund, LLC, Tax Matters Partner, Petitioner v. Commissioner of Internal Revenue, Respondent". 1