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RERI HOLDINGS I, LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 9324-08.

143 T.C. 41 (2014)

RERI HOLDINGS I, LLC, HAROLD LEVINE, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 11, 2014.

Attorney(s) appearing for the Case

Randall Gregory Dick and Rebekah E. Schechtman, for petitioner.

Travis Vance III,   Kristen I. Nygren,   John M. Altman, and Leon St. Laurent, for respondent.

OPINION

This is a partnership-level action brought in response to a notice of final partnership administrative adjustment. The action involves RERI Holdings I, LLC (RERI). On its 2003 income tax return RERI reported a charitable contribution of property worth $33,019,000. Respondent determined that RERI overstated the value...

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