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BLAU v. C.I.R.

No. 17-1266.

924 F.3d 1261 (2019)

Jeff BLAU, Tax Matters Partner of Reri Holdings I, LLC, Appellant v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided May 24, 2019.

Attorney(s) appearing for the Case

Kathleen Pakenham argued the cause for appellant. With her on the briefs were Stephen D. Gardner , Adriana Lofaro Wirtz , and Clint Massengill.

Jacob Earl Christensen , Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief was Richard Farber , Attorney.

Before: Rogers and Millett, Circuit Judges, and Ginsburg, Senior Circuit Judge.

RERI Holdings, LLC (RERI) claimed a charitable contribution deduction of $ 33 million on its 2003 federal tax return. The Internal Revenue Service determined that RERI was not entitled to this deduction and imposed a 40% penalty for underpayment of tax. RERI unsuccessfully challenged both rulings before the Tax Court...

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