Plateau Holdings, LLC v. Commissioner, T.C. Order (June 24, 2022)
About This Legal Opinion
In this June 2022 order, the Tax Court denied an untimely motion for reconsideration whereby the taxpayer asked the court to consider the impact of the 11th Circuit’s opinion in Hewitt that invalidated a portion of the proceeds regulation. Judge Lauber noted that the taxpayer never contested the validity of the regulation in its proceedings, and that the second prong of the decision, on the prior claims issue, might remain good law, depending on how broadly Hewitt is interpreted.
State: Tennessee
Procedural Status: Case active.
Date: 2022
Keywords: Appraisal; appraisal penalties; charitable deduction; comparable sales; contiguous parcels; enhancement; Form 8283; good faith; highest and best use; Internal Revenue Code; negligence; parol evidence; private conservation easement; proceeds provision; reasonable cause; savings clause; syndication; valuation.
Disclaimer
These resources are provided "as is" for informational purposes only, without warranty of any kind. They do not constitute legal or professional advice and do not create an attorney-client relationship. They may not reflect current legal developments and should be adapted for your organization with qualified professional help. The Alliance is not liable for any damages arising from use of or reliance on these resources. Views in individual posts and third-party links/logos are not Alliance endorsements. The Alliance is committed to equal opportunity and does not condone unlawful discrimination.
For accreditation-related materials, please also consult the Land Trust Accreditation Commission website.