Peking Inv. Fund, LLC v. Comm'r
United States Tax Court
Participant, T, acting on behalf of Peking Investment Fund, LLC (PIF), as PIF's tax matters partner (TMP), executed a series of consents extending the I.R.C. sec. 6229(a) periods of limitations for making assessments (periods of limitations) with respect to PIF's 2001-04 taxable years (years in issue) until Dec. 31, 2008. T executed those consents pursuant to his appointment as PIF's TMP by H, acting on behalf of CMI, PIF's member-manager and its then TMP.
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Participant, T, acting on behalf of Peking Investment Fund, LLC (PIF), as PIF's tax matters partner (TMP), executed a series of consents extending the I.R.C. sec. 6229(a) periods of limitations for making assessments (periods of limitations) with respect to PIF's 2001-04 taxable years (years in issue) until Dec. 31, 2008. T executed those consents pursuant to his appointment as PIF's TMP by H, acting on behalf of CMI, PIF's member-manager and its then TMP. R's agent auditing PIF's returns for the years in issue was notified of that appointment, and he solicited and accepted the consents in…
1Opinion of the Court
PEKING INVESTMENT FUND, LLC, PEKING INVESTMENT HOLDINGS LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Peking Inv. Fund, LLC v. Comm'r
Docket No. 12772-09
United States Tax Court
T.C. Memo 2013-288; 2013 Tax Ct. Memo LEXIS 302; 106 T.C.M. (CCH) 688;
December 23, 2013, Filed
An appropriate order will be issued granting in part respondent's cross-motion and denying participant's motion for summary judgment.
Participant, T, acting on behalf of Peking Investment Fund, LLC (PIF), as PIF's tax matters partner (TMP), executed a series of consents extending the I.R.C.…
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