Legal Opinion
Coal Property Holdings, LLC, Coal Land Manager, LLC, Tax Matters Partner v. Commissioner
United States Tax Court
Decided October 28, 2019No. 27778-16Unknown
1Opinion of the Court
153 T.C. No. 7
UNITED STATES TAX COURT COAL PROPERTY HOLDINGS, LLC, COAL LAND MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27778-16. Filed October 28, 2019. In 2013 P donated a conservation easement to a qualified or- ganization. The easement deed provided that, if the property were sold following judicial extinguishment of the easement, the donee organization would receive a share of the proceeds, “after the satis- faction of prior claims,” determined by a formula. Under the formula, the donee’s share was equal to the property’s fair…
2Cases cited10 opinions
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Commissioner of Internal Revenue v. ProcterCourt of Appeals for the Fourth Circuit · 1944
- PBBM-Rose Hill, Ltd. v. Comm'r of Internal RevenueCourt of Appeals for the Fifth Circuit · 2018
- B. Belk, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 2014
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