George C. Huff (petitioner) vs. IRS (respondent) is an example of what happens when you do not read my blog.. just kiddin’

Today the Tax Court allowed George to ramble on for 23 pages why his U.S.V.I. tax ploy should work.  George asked the Court to tell the IRS to go away.   Yes, seriously.

George believes he was living in the Virgin Islands with income from a  Virgin Islands limited partnership, named NASCO.

As you tax guys now, the law requires the IRS to issue the assessment notice via the partnership.  Clever, very clever…but only if you had a foreign partnership.

As my blog and book readers know all limited liability foreign entities are not partnerships.  They’re corporations[1].  So, as George discovered on the last page the Court wrote “Because we conclude that NASCO is not classified as a partnership for Federal tax purposes …petitioner’s motion will be denied.”

So, George gets to return to tax court to fend off the IRS.

If you would like a copy of the tax court case, please let me know at brian@intltaxcounselors.com.