Wachter v. Comm'r
United States Tax Court
For 2004 through 2006 Ps reported charitable contributions that flowed to them from a partnership and an LLC, both of which were treated as partnerships for tax purposes. For each year the LLC reported charitable contributions of cash and the partnership reported bargain sales of conservation easements as charitable contributions of property.
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For 2004 through 2006 Ps reported charitable contributions that flowed to them from a partnership and an LLC, both of which were treated as partnerships for tax purposes. For each year the LLC reported charitable contributions of cash and the partnership reported bargain sales of conservation easements as charitable contributions of property. R issued notices of deficiency to Ps disallowing all of the charitable contribution deductions and determining accuracy-related penalties. R filed a motion for partial summary judgment asserting that Ps did not satisfy the "contemporaneous written…
1Opinion of the Court
PATRICK J. WACHTER AND LOUISE M. WACHTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent;
MICHAEL E. WACHTER AND KELLY A. WACHTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wachter v. Comm'r
Docket Nos. 9213-11, 9219-11.
United States Tax Court
142 T.C. 140; 2014 U.S. Tax Ct. LEXIS 8; 142 T.C. No. 7;
March 11, 2014, Filed
An appropriate order will be issued.
For 2004 through 2006 Ps reported charitable contributions that flowed to them from a partnership and an LLC, both of which were treated as partnerships for tax purposes. For each year the LLC reported charitable…
2Cases cited20 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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