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Post details: "Check-the-Box" Regulations Valid; LLC's Sole Member Liable for Unpaid Employment Taxes (Medical Practice Solutions, LLC, TC)
04/01/09
"Check-the-Box" Regulations Valid; LLC's Sole Member Liable for Unpaid Employment Taxes (Medical Practice Solutions, LLC, TC)
CCH (cch.taxgroup.com) reports:
"Check-the-box" regulations in effect at the time the sole member of an LLC made an LLC election were valid and reasonable, even though subsequent amendments to the regulations resulted in different effects on employment tax reporting and liability. The regulations allowed collection of the LLC's unpaid employment taxes from the individual, who could chose the entity's form and, thus, the consequences of her choice. The analysis and result in Litriello, CA-6, 2007-1 USTC ¶50,426, were adopted.
Medical Practice Solutions, LLC, 132 TC No.7, Dec. 57,778
Other References:
Code Sec. 7701
CCH Reference - 2009FED ¶43,084.48
Tax Research Consultant
CCH Reference - TRC PART: 3,102
CCH Reference - TRC STAGES: 6,204
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