Legal Opinion
Harbor Lofts Associates, Crowninshield Corporation, Tax Matters Partner v. Commissioner
United States Tax Court
Decided August 27, 2018No. 993-17Unknown
1Opinion of the Court
151 T.C. No. 3
UNITED STATES TAX COURT HARBOR LOFTS ASSOCIATES, CROWNINSHIELD CORPORATION, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 993-17. Filed August 27, 2018. E, a nonprofit development corporation, is the fee simple owner of two buildings listed on the National Register of Historic Places. H, a partnership, is a long-term lessee of those buildings. In 2009, H and E joined together in transferring a facade easement to a qualified organization under I.R.C. sec. 170(h)(3). H claimed a charitable contribution deduction of $4,457,515 for 2009.…
2Cases cited9 opinions
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- Naftel v. CommissionerUnited States Tax Court · 1985
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