Belair Woods, LLC, Effingham Managers, LLC, Tax Matters Partner v. Commissioner

154 T.C. No. 1

UNITED STATES TAX COURT BELAIR WOODS, LLC, EFFINGHAM MANAGERS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19493-17. Filed January 6, 2020. P is the tax matters partner of LLC, which claimed on its 2009 return a charitable contribution deduction for a conservation ease- ment. R commenced an examination of LLC’s return and secured from an IRS engineer a report concluding that LLC had substantially overvalued the easement. R’s agent sent P a Letter 1807 inviting P to a closing confer- ence to discuss R’s tentative proposed…