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BOLTAR, L.L.C. v. COMMISSIONER

Docket No. 25954-08.

136 T.C. 326 (2011)

BOLTAR, L.L.C., JOSEPH CALABRIA, JR., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 5, 2011.

Attorney(s) appearing for the Case

James R. Walker , Justin D. Cumming , and Christopher D. Freeman , for petitioner.

Steven I. Josephy and Miles B. Fuller , for respondent.

COHEN, Judge:

In a notice of final partnership administrative adjustment (FPAA) for 2003, respondent allowed only $42,400 out of $3,245,000 claimed as a charitable contribution deduction on the partnership return of Boltar, L.L.C. (Boltar). The deduction was claimed for the donation of a conservation easement on a portion of real property owned by Boltar and located in Lake County, Indiana.

Prior to trial, respondent filed a motion in limine to exclude...

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