Wendell Falls Development, LLC, Gregory Alan Ferguson, Tax Matters Partner v. Commissioner

T.C. Memo. 2018-45

UNITED STATES TAX COURT WENDELL FALLS DEVELOPMENT, LLC, GREGORY ALAN FERGUSON, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3494-14. Filed April 4, 2018. David M. Wooldridge and Thomas Allen Worth, for petitioner. Scott Lyons and Johnny Craig Young, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MORRISON, Judge: Wendell Falls Development, LLC was a limited liability corporation treated as a partnership for federal tax purposes. For Wendell Falls’ 2007 taxable year, the respondent (hereinafter “the IRS”) issued a notice…