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CAPITOL PLACES II OWNER, LLC v. COMMISSIONER

Docket No. 16536-23.

164 T.C. No. 1

CAPITOL PLACES II OWNER, LLC, HISTORIC PRESERVATION FUND 2014 LLC, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 2, 2025.

Attorney(s) appearing for the Case

Sarah L. Ray, Frank Agostino, Michelle A. Levin, Sarah E. Green, and Logan C. Abernathy, for petitioner.

David N. Stock, Joseph E. Nagy, Anita A. Gill, Sahir Rama, Mark J. Miller, William M. Rowe, and Kathryn E. Kelly, for respondent.

OPINION

Capital Places II Owner, LLC (CPII), donated a facade easement in December 2014 over the Manson Building (Building), an early 20th-century design located in a historic district of Columbia, South Carolina. De rigueur CPII claimed a hefty charitable contribution deduction (more than $23 million) for agreeing...

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