Thompson v. United States

OPINION and ORDER

BLOCK, Judge.

I. INTRODUCTION

The nub of this ease is whether the government is collecting more taxes than written law and regulation allow. More precisely, plaintiff James R. Thompson structured his business activity in the form of a limited liability company (“LLC”) under the laws of the State of Texas. LLCs are hybrid entities that under state law are neither part*730nerships nor corporations. See generally AlaN Bromberg & Larry Ribstein, Bromberg and Ribstein on Partnership (“Bromberg”) § 1.01(b)(4) (2007). Nevertheless, under the Treasury Regulations, an LLC must choose to be…