IPO II, A Partnership, Gerald R. Forsythe, Tax Matters Partner v. Commissioner

122 T.C. No. 17

UNITED STATES TAX COURT IPO II, A PARTNERSHIP, GERALD R. FORSYTHE, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14500-02. Filed April 23, 2004. IPO II, an LLC but treated as a partnership for Federal income tax purposes, is owned by IO, an S corporation, and F, an individual. F owns 100 percent of the outstanding stock in IO, 70 percent of the outstanding stock of IE, an S corporation, and 63 percent of the outstanding stock of IP, a C corporation. F’s daughters own the remaining 30 percent of the outstanding stock of IE. IPO II…