John L. Roth & Deanne M. Roth v. Commissioner

T.C. Memo. 2017-248

UNITED STATES TAX COURT JOHN L. ROTH AND DEANNE M. ROTH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5544-12. Filed December 28, 2017. Ps overstated by more than 200% the value of a conservation easement donated during the taxable year 2007. R’s examiner determined that Ps were liable for the 40% gross valuation misstatement penalty under I.R.C. sec. 6662(h) and obtained written approval from her immediate supervisor. The notice of deficiency ultimately issued to Ps was based on R’s Appeals officer’s closing memorandum, for which he obtained…