Atlantic Pacific Management Group LLC v. Commissioner

152 T.C. No. 17

UNITED STATES TAX COURT ATLANTIC PACIFIC MANAGEMENT GROUP, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8412-18. Filed June 20, 2019. In this collection due process (CDP) case R assessed penalties under I.R.C. sec. 6698(a) against P for late partnership information return filings for 2014 and 2015 and a penalty under I.R.C. sec. 6038(b) for failing to file an information return with respect to certain foreign corporations and partnerships for 2014. R filed a notice of Federal tax lien and mailed a notice of Federal tax lien filing to P. P did not…