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Re: BBANBOB post# 652069

Friday, 03/19/2021 12:38:45 PM

Friday, March 19, 2021 12:38:45 PM

Post# of 727646
If the trust were closed, I would expect the trust would have to formally substitute the wind up officers in its stead in the appeal with a court filing. The appellee would have to still exist short of that filing. A corporation or trust cannot simply dissolve itself to rid itself of pending litigation. Also, I do not think an extension was required because Class 18 already got their distributions. It is my understanding that the Treasury Regulation and Private Letter Rulings are aimed at ensuring the IRS that all distributions were to be made by a certain time. Hence unlikely the IRS cares about a few weeks, and we know the trust has a reputation for skirting what is clearly written.
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