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PLR 199914006 - An LLC With 2 Members Was A Disregarded Entity

2024-12-19

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Today we published a chart of PLR 199914006. This PLR held that an LLC with two members should be treated as a disregarded entity. The second member had no right to receive any distributions, income, gain, profit, loss, deduction, credit, or other amount from the LLC. In other words, the second member had no economic rights.

This PLR is similar to PLR 200201024, which we charted back in 2007.

(Number of charts published to date: 1,464)

Tags: 701 Partnerships, 7701-3 Check-the-Box Elections, Charts - Situational Charts, Other - Form vs. Substance