In Block Developers LLC et al. v. Commissioner, T.C. Memo. 2017-142, the Tax Court held that the IRS was not required to notify a partnership’s indirect partners of the beginning of administrative proceedings. In addition, it held that the partnership was used as a conduit to transfer funds to the indirect partners’ Roth IRAs and that the transfers were excess contributions subject to excise taxes.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.