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mordicai

03/19/21 12:38 PM

#652079 RE: BBANBOB #652069

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.