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SMALDINO v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 5437-18.

T.C. Memo. 2021-127

LOUIS P. SMALDINO, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 10, 2021.

Attorney(s) appearing for the Case

Lavonne D. Lawson and Charles W. Morris , for petitioner.

Jenny R. Casey , Emerald G. Smith , and Kim-Khanh Nguyen , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

Petitioner owned and operated numerous rental properties in southern California. He placed 10 of these properties in Smaldino Investments, LLC (LLC), which he owned through a revocable trust. In 2013 he transferred about 8% of the LLC class B member interests to the Smaldino 2012...

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