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PLATEAU HOLDINGS, LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 12519-16.

T.C. Memo. 2021-133

PLATEAU HOLDINGS, LLC, WATERFALL DEVELOPMENT MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

United States Tax Court.

Filed November 30, 2021.

Attorney(s) appearing for the Case

Christopher S. Rizek and Scott D. Michel , for petitioner.

Shannon E. Craft , Rebeccah L. Bower , and John T. Arthur , for respondent.

MEMORANDUM OPINION

This case involves a charitable contribution deduction claimed by Plateau Holdings, LLC (Plateau), for conservation easements. On its 2012 Federal income tax return Plateau claimed a deduction of $25,449,000 for the donation of the easements. On June 23, 2020, we issued an opinion, Plateau Holdings...

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