Legal Opinion
PBBM-Rose Hill, Ltd. v. Comm'r of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided August 14, 2018No. 17-60276PublishedCited by 32 opinions
1Opinion of the Court
KING, Circuit Judge:
For the 2007 tax year, PBBM Rose Hill, Ltd., claimed a charitable contribution deduction of $15,160,000 for its donation of a conservation easement to the North American Land Trust. Subsequently, the Commissioner of Internal Revenue issued a final partnership administrative adjustment that determined PBBM Rose Hill, Ltd., was not entitled to the deduction and assessed a penalty for the overvaluation of the conservation easement. PBBM Rose Hill, Ltd., and its tax matters partner, PBBM Corp., filed a petition for readjustment in tax court. The tax court concluded that the…
2Cases cited34 opinions
- Auer v. RobbinsSupreme Court of the United States · 1997
- Christensen v. Harris CountySupreme Court of the United States · 2000
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- United States v. WoodsSupreme Court of the United States · 2013
- Mary Smith v. Regional Transit Authority, eCourt of Appeals for the Fifth Circuit · 2016
29 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Oakbrook Land Holdings, LLC v. Comm'r of Internal Rev.Court of Appeals for the Sixth Circuit · 2022
- Jeff Blau, Tax Matters Partner of RERI Holdings I, LLC v. Commissioner of IRSCourt of Appeals for the D.C. Circuit · 2019
- TOT Property Holdings, LLC v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2021
- David F. Hewitt v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2021
- Hoffman Properties II v. CIRCourt of Appeals for the Sixth Circuit · 2020
27 more not listed; retrieve them via the Exa API.