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BELAIR WOODS, LLC v. COMMISSIONER

Docket No. 19493-17.

154 T.C. 1 (2020)

154 T.C. No. 1

BELAIR WOODS, LLC, EFFINGHAM MANAGERS, LLC, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 6, 2020.

Attorney(s) appearing for the Case

David M. Wooldridge , Ronald Levitt , Gregory P. Rhodes , and Michelle A. Levin , for petitioner.

Christopher D. Bradley , Jason P. Oppenheim , John W. Sheffield III , and John T. Arthur , for respondent.

OPINION

This case involves a charitable contribution deduction claimed by Belair Woods, LLC (Belair), for a conservation easement. The Internal Revenue Service (IRS or respondent) issued a timely notice of final partnership administrative adjustment (FPAA) disallowing that deduction in its entirety and determining four penalties...

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