Legal Opinion

Partita Partners LLC v. United States

District Court, S.D. New York

Decided July 10, 2017No. 15-cv-2561 (PKC)Published

1Opinion of the Court

MEMORANDUM AND ORDER

P. Kevin Castel, United States District Judge

In 2008, plaintiff Partita Partners LLC (“Partita”) claimed a federal tax deduction of $4,186,000 for the donation of a preservation easement in the fagade of a building that it owns on the Upper East Side, The Italianate-style building was constructed in the 1870s, and it has been a part of the Upper East Side Historic District since 1981. Partita made its donation to the Trust for Architectural Easements, and, as part of its deed of easement, reserved *6852,700 square feet for future development rights.

The IRS disallowed the…

2Cases cited14 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Shelley Weinstock v. Columbia UniversityCourt of Appeals for the Second Circuit · 2000
  3. Jaramillo v. Weyerhaeuser Co.Court of Appeals for the Second Circuit · 2008
  4. John Delaney v. Bank of America Corp.Court of Appeals for the Second Circuit · 2014
  5. United States v. WoodsSupreme Court of the United States · 2013

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