In this administrative ruling, the an LLC was owned by a state entity and a foreign entity. An unknown person signed the signature line on Form 1065 as "Foreign Entity." The individual taxpayer that acted on behalf of the foreign entity did not file the return and indicated that someone from the tax preparer's office signed the partnership signature line. The IRS determined that the Form 1065 was not valid because it wasn't signed by a general partner of LLC member manager, citing Agri-Cal Venture Associates v. Comr., T.C. Memo. 2000-271. But, the invalid return does start the running of the statute of limitations period at issue for purposes of the taxpayer whose liability is being assessed, but not the statute of limitations for the partnership of LLC whose return might also report the transaction giving rise to the liability. C.C.A. 201425011 (Feb. 21, 2014).