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SAVANNAH SHOALS, LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 3412-22.

T.C. Memo. 2024-35

SAVANNAH SHOALS, LLC, GREEN CREEK RESOURCES, LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 26, 2024.

Attorney(s) appearing for the Case

Jeffrey S. Luechtefeld , Hale E. Sheppard , John W. Hackney , Sean R. Gannon , and William A. Stone , for petitioner.

Christopher D. Bradley , Vassiliki Economides Farrior , Stephen A. Haller , Rubinder K. Bal , Edward A. Waters , Victoria J. Kanrek , Jeannette D. Pappas , and Alexandra E. Nicholaides , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

On December 28, 2017, more than a 50% membership interest in Savannah Shoals, LLC (Shoals), a partnership for federal tax purposes, was sold, triggering its technical termination under section 708(b)(1)(B).1 See § 708(b)(1)(B) (requiring a technical...

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