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PALMOLIVE BLDG. INV'RS, LLC v. COMMISSIONER

Docket No. 23444-14.

149 T.C. 380 (2017)

149 T.C. No. 18

PALMOLIVE BUILDING INVESTORS, LLC, DK PALMOLIVE BUILDING INVESTORS PARTICIPANTS, LLC, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 10, 2017.

Attorney(s) appearing for the Case

Jeffrey H. Paravano and Michelle M. Hervey, for petitioner.

David A. Lee, Thomas F. Harriman, Elizabeth Y. Williams, and Robert J. Basso, for respondent.

CONTENTS

Background                                                           383

      The property and the charitable donation                       383
      The mortgage and its "subordination"                           384
      The Deed                                                       385
      The IRS's examination, the FPAA, and the petition              388

Discussion                                                           388

I....

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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