Legal Opinion

Pine Mountain Preserve, LLLP f.k.a. Chelsea Preserve, LLLP, Eddleman Properties, LLC, Tax Matters Partner v. Commissioner

United States Tax Court

Decided December 27, 2018No. 8956-13Unknown

1Opinion of the Court

151 T.C. No. 14

UNITED STATES TAX COURT PINE MOUNTAIN PRESERVE, LLLP f.k.a. CHELSEA PRESERVE, LLLP, EDDLEMAN PROPERTIES, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8956-13. Filed December 27, 2018. P acquired a tract of land near Birmingham, Alabama, and conveyed to a qualified land trust, in 2005, 2006, and 2007, ease- ments covering relatively small portions of that property. Each easement defined a conservation area that was to be restricted in perpetuity from commercial and residential development, with a carve-out in the 2005 and 2006…

2Cases cited25 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  4. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  5. Estate of Gilford v. CommissionerUnited States Tax Court · 1987

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