TOT PROPERTY HOLDINGS, LLC v. CIR

No. 20-11050.

1 F.4th 1354 (2021)

TOT PROPERTY HOLDINGS, LLC, TOT Land Manager, LLC, Tax Matters Partner, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

June 23, 2021.


Attorney(s) appearing for the Case

John Paul Barrie , Bryan Cave, LLP, New York, NY, Eric P. Schroeder , Brian McKinley Underwood, Jr. , Bryan Cave Leighton Paisner, LLP, Atlanta, GA, Kenneth Lee Marshall , Bryan Cave Leighton Paisner, San Francisco, CA, Barbara Anne Smith , Bryan Cave Leighton Paisner, LLP, Saint Louis, MO, for Petitioners-Appellants.

Anthony T. Sheehan , Francesca Ugolini , U.S. Department of Justice, Appellate Section Tax Division, Michael J. Desmond , Chief Counsel — IRS, Washington, DC, for Respondent-Appellee.

Before LAGOA, ANDERSON, and MARCUS Circuit Judges.


Whether the taxpayer in this case could properly claim a deduction turns on whether language in a deed was an unenforceable savings clause, dependent on a condition subsequent, or a valid interpretive clause. The deed at issue donated for conservation purposes an easement encumbering the taxpayer's property. The Internal...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases