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15 W. 17TH ST. LLC v. COMMISSIONER

Docket No. 25152-11.

147 T.C. 557 (2016)

T.C. Memo. 2016-233

15 WEST 17TH STREET LLC, ISAAC MISHAN, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 22, 2016.

Attorney(s) appearing for the Case

Jeremy M. Klausner , Frank Agostino , and Lawrence Sannicandro , for petitioner.

Marc L. Caine and Carina Campobasso , for respondent.

OPINION

This case is before the Court on petitioner's motion for partial summary judgment. The motion presents a question of statutory construction involving the relationship between subparagraphs (A) and (D) of section 170(f)(8), which governs substantiation requirements for certain...

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