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RP GOLF v. C.I.R.

No. 16-3277.

860 F.3d 1096 (2017)

RP GOLF; SB Golf, LLC, Tax Matters Partner, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Eighth Circuit.

Filed: June 26, 2017.

Attorney(s) appearing for the Case

Counsel who presented argument on behalf of the petitioner was Brian C. Walsh , of Saint Louis, MO. The following attorney(s) appeared on the appellant brief; Brian C. Walsh , of Saint Louis, MO., John Paul Barrie , of New York, NY.

Counsel who presented argument on behalf of the respondent was Francesca Ugolini , of Washington, DC. The following attorney(s) appeared on the appellee brief; Francesca Ugolini , of Washington, DC., Andrew Weiner , of Washington, DC.

Before SMITH, BENTON and SHEPHERD, Circuit Judges.

RP Golf, LLC claimed a charitable deduction of $16.4 million on its 2003 tax return for donating an easement to the Platte County Land Trust (PLT). The Commissioner of Internal Revenue disallowed the deduction, finding RP Golf did not make a "qualified contribution easement" under 26 U.S.C. § 170(b)(1)(E). After trial...

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