PARK LAKE II, LLC v. COMMISSIONER

Docket No. 12115-20.

T.C. Memo. 2025-11

PARK LAKE II, LLC, PARK LAKE PARTNERS, LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed January 30, 2025.


Attorney(s) appearing for the Case

Adam R. Young and Vivian D. Hoard, for petitioner.

Anne M. Wurtzebach, Abigail F. Dunnigan, Ashley M. Van Fleet, and Steven Tillem, for respondent.


MEMORANDUM OPINION

This case involves a charitable contribution deduction claimed for 2016 by Park Lake II, LLC (Park Lake), for the donation of a conservation easement. The Internal Revenue Service (IRS or respondent) issued a notice of Final Partnership Administrative Adjustment (FPAA) disallowing the deduction and determining...

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