Opinion
2330-21
03-23-2022
MM Terry Ranch, LTD., MM Terry Holdings/Ranch, LLC, A Partner Other Than the Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On January 5, 2021, petitioner filed the petition in this case. Petitioner states in the petition that petitioner is the tax matters partner. The petition was 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 tax matters partner, 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 "MM Terry Ranch, LTD., MM Terry Holdings/Ranch, LLC, Tax Matters Partner, Petitioner v. Commissioner of Internal Revenue, Respondent".