Letko v. United States

In the United States Court of Federal Claims No. 22-1268 Filed: May 1, 2025 ) JON LETKO, in his capacity as Tax ) Matters Partner of U.S. Healthcare ) Supply, LLC, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ) Thomas A. Gentile, Wilson Elser Moskowitz Edelman & Dicker LLP, Florham Park, NJ, for plaintiff. Emily J. Van Dam, U.S. Department of Justice - Tax Division, Washington, DC, for defendant. OPINION AND ORDER When the Internal Revenue Service (“IRS”) makes a post-audit “adjustment” to a partnership’s return, the tax matters partner (“TMP”) of the partnership can petition…