Irby v. Comm'r
United States Tax Court
Ps are members of an LLC which conveyed conservation easements encumbering two parcels of land (one conveyance in 2003 and the other in 2004) to COL, a qualified organization as defined in I.R.C sec. 170(h)(3), in bargain sale transactions. The purchase portion of the transactions was funded with grants from Federal, State, and county agencies which were established to assist in the conservation of open land.
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Ps are members of an LLC which conveyed conservation easements encumbering two parcels of land (one conveyance in 2003 and the other in 2004) to COL, a qualified organization as defined in I.R.C sec. 170(h)(3), in bargain sale transactions. The purchase portion of the transactions was funded with grants from Federal, State, and county agencies which were established to assist in the conservation of open land. The LLC reported gain with respect to the sale portion and a charitable contribution with respect to the remaining portion (the bargain portion) of the transactions. Ps reported their…
1Opinion of the Court
OPINION
JACOBS, Judge:
Charles Irby, Irene Irby, Dale Irby, and Stanley Irby (sometimes referred to as the Irbys or petitioners) are members of Irby Ranches, LLC, a Colorado limited liability company that elected to be taxed as a partnership for 2003 and 2004. As discussed in greater detail infra, Irby Ranches, LLC, conveyed to Colorado Open Lands, a “qualified organization” as defined in section 170(h)(3), two conservation easements: one in 2003 which encumbered approximately 197 acres of land and a second in 2004 which encumbered approximately 456 acres of land. The easements placed on the…
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- Addis v. Comm'rUnited States Tax Court · 2002
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- Kaufman v. ShulmanCourt of Appeals for the First Circuit · 2012
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3Cited by13 opinions
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