Peter C. Emanouil & Pascale Emanouil v. Commissioner

T.C. Memo. 2020-120

UNITED STATES TAX COURT PETER C. EMANOUIL AND PASCALE EMANOUIL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5089-17. Filed August 17, 2020. P-H is a real estate developer. In 1999 he purchased 197 acres of undeveloped property in Town W. Over the next several years, P-H made various attempts to either develop or sell the 197 acres. Ultimately, P-H obtained approval for an affordable housing project (“AHP”) including 164 units on 104 of the 197 acres. Throughout the approval process P-H made various concessions to mitigate Town W’s concerns…