Englewood Place, LLC, Effingham Managers, LLC, Tax Matters Partner v. Commissioner

T.C. Memo. 2020-105

UNITED STATES TAX COURT ENGLEWOOD PLACE, LLC, EFFINGHAM MANAGERS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1560-18. Filed July 9, 2020. Anson H. Asbury, Ethan J. Vernon, and Gilbert L. Carey, Jr., for petitioner. Christopher D. Bradley, Jason P. Oppenheim, John W. Sheffield III, and John T. Arthur, for respondent. MEMORANDUM OPINION LAUBER, Judge: This is one of many cases in this Court involving char- itable contribution deductions for conservation easements. Currently before the Court are cross-motions for partial…