RERI Holdings I, LLC v. Commissioner
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Belair Woods, LLC v. Commissioner
IRS disallowed a CE deduction in full due to missing basis on Form 8283.Tax Court found for the IRS that taxpayer had not substantially complied and that the information is reasonably obtainable and necessary. The tax court follows that of RERI Holdings I, LLC v. Commissioner, 149 T.C. No. 1.
Lumpkin HC, LLC v. Commissioner
In a proceeds clause case with the improvement deduction language, the Tax Court denied the deductions in full, following Oakbrook Land Holdings LLC, v. Commissioner and Coal Property Holdings, LLC v. Commissioner. The Tax Court declined to consider the IRS' argument on the floating building areas.
Lumpkin One Five Six, LLC v. Commissioner
Lumpkin One Five Six LLC v. Commissioner - June 2020.pdf In a proceeds clause case with the improvement deduction language, the Tax Court denied the deductions in full, following Oakbrook Land Holdings LLC, v. Commissioner and Coal Property Holdings, LLC v. Commissioner. The Tax Court declined to consider the IRS' argument on the floating building areas.
TOT Property Holdings, LLC v. Commissioner
In 2005, George Dixson purchased 652 acres of undeveloped land for $486,000 that was later transferred into the TOT Property Holdings, LLC (LLC). In December 2013, an investor purchased 99% of LLC shares for $1,039,000, then claimed a charitable deduction of $6.9 million on a conservation easement.
Piedmont Breeze, LLC v. Commissioner
Railroad Holdings, LLC v. Commissioner
In 2012, Railroad Holdings LLC granted conservation easement on 452-acre parcel to the SE Regional Land Conservancy and claimed a $16 million charitable contribution deduction. The easement contained a termination proceeds provision that differed from the language of Reg. § 1.170A-14(g)(6)(ii).