Route 231, LLC, John Carr v. Commissioner of IRS

Affirmed by published opinion.

Judge AGEE wrote the opinion, in which Judge WYNN and Senior Judge HAMILTON joined.

AGEE, Circuit Judge:

Route 231, LLC, a Virginia limited liability company, (“Route 231”) reported capital contributions of $8,416,000 on its 2005 federal tax return. 1 This number reflected, in relevant part, $3,816,000 it received from one of its members, Virginia Conservation Tax Credit FD LLLP (“Virginia Conservation”). Upon audit, the Commissioner of the Internal Revenue Service issued a Final Partnership Administrative Adjustment (“FPAA”) indicating that Route 231 should have…