BC Ranch II, L.P. v. Commissioner

WIENER, Circuit Judge:

Petitioners-Appellants, BC Ranch I, L.P. (“BCR I”), and B.C. Ranch II, L.P. (“BCR II”), (collectively the “BCR Partnerships” or “Appellants”), claim that Respondent-Appellee, the Commissioner of Internal Revenue (the “Commissioner”), wrongfully disallowed their charitable deductions for two conservation easements. Appellants contend that in ruling for the Commission, the Tax Court wrongfully classified the sale of limited partnership interests as disguised sales and wrongfully imposed a gross valuation misstatement penalty. We vacate and remand.

I

Facts and Proceedings

A.…