Amanda Iris Gluck Irrevocable Trust v. Commissioner

154 T.C. No. 11

UNITED STATES TAX COURT AMANDA IRIS GLUCK IRREVOCABLE TRUST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5760-19L. Filed May 26, 2020. P was a direct and indirect partner in partnerships subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982. See I.R.C. secs. 6221-6234 (as in effect for years before 2018). In 2012 one of the partnerships in which P held an indirect interest sold property and realized a large capital gain. P allegedly failed to report its entire distributive share of that gain. R…