Legal Opinion

Whitehouse Hotel L.P. v. Comm'r

United States Tax Court

Decided October 30, 2008No. 12104-03Published

The parties agree that W, a partnership, is entitled to a charitable contribution deduction on account of its having made a qualified conservation contribution to a qualified organization. They disagree as to the amount of the contribution.

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The parties agree that W, a partnership, is entitled to a charitable contribution deduction on account of its having made a qualified conservation contribution to a qualified organization. They disagree as to the amount of the contribution. They further disagree as to whether, if W overstated the amount of the deduction, the overstatement amounted to a substantial valuation misstatement or a gross valuation misstatement and, if either, whether any resulting accuracy-related penalty is excused on account of reasonable cause. P also objects to the appraisal testimony of R's expert witness, A,…

1Opinion of the Court

WHITEHOUSE HOTEL LIMITED PARTNERSHIP, QHR HOLDINGS-NEW ORLEANS, LTD., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Whitehouse Hotel L.P. v. Comm'r

No. 12104-03

United States Tax Court

131 T.C. 112; 2008 U.S. Tax Ct. LEXIS 28; 131 T.C. No. 10;

October 30, 2008, Filed

The parties agree that W, a partnership, is entitled to a

charitable contribution deduction on account of its having made a qualified conservation contribution to a qualified organization. They disagree as to the amount of the contribution. They further disagree as to whether, if W overstated the amount…

2Cases cited45 opinions

  1. Daubert v. Merrell Dow Pharmaceuticals, Inc.Supreme Court of the United States · 1993
  2. Kumho Tire Co. v. CarmichaelSupreme Court of the United States · 1999
  3. Helvering v. National Grocery Co.Supreme Court of the United States · 1938
  4. Jules R. Viterbo, Et Ux, (Patricia Viterbo) v. The Dow Chemical Co.Court of Appeals for the Fifth Circuit · 1987
  5. United States v. 14.38 Acres of Land, More or Less Situated in Leflore County, MississippiCourt of Appeals for the Fifth Circuit · 1996

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