Cave Buttes, L.L.C. v. Comm'r
United States Tax Court
A limited liability company (C) sold property to the Maricopa Flood Control District for what it believed was less than fair market value. C obtained an appraisal of the property and took a charitable contribution deduction for the difference between the sale price and the appraised fair market value. R denied the charitable contribution deduction in its entirety, believing that C failed to comply with the substantiation requirements for charitable contributions.
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A limited liability company (C) sold property to the Maricopa Flood Control District for what it believed was less than fair market value. C obtained an appraisal of the property and took a charitable contribution deduction for the difference between the sale price and the appraised fair market value. R denied the charitable contribution deduction in its entirety, believing that C failed to comply with the substantiation requirements for charitable contributions. R asserted that C failed to attach a qualified appraisal report to its return and that it also failed to use a qualified appraiser.…
1Opinion of the Court
CAVE BUTTES, L.L.C., MICHAEL WOLFE, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cave Buttes, L.L.C. v. Comm'r
Docket No. 5788-11.
United States Tax Court
2016 U.S. Tax Ct. LEXIS 27; 147 T.C. No. 10;
September 20, 2016, Filed
A limited liability company (C) sold property to the Maricopa Flood Control District for what it believed was less than fair market value. C obtained an appraisal of the property and took a charitable contribution deduction for the difference between the sale price and the appraised fair market value. R denied the charitable contribution…
2Cases cited47 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- United States v. MillerSupreme Court of the United States · 1943
- Olson v. United StatesSupreme Court of the United States · 1934
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Bond v. CommissionerUnited States Tax Court · 1993
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