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BC RANCH II, L.P. v. C.I.R.

No. 16-60068, Cons w/16-60069.

867 F.3d 547 (2017)

BC RANCH II, L.P., also known as Bosque Canyon Ranch II, L.P.; BC Ranch I, Incorporated, Tax Matters Partner, Petitioners-Appellants v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Bosque Canyon Ranch, L.P.; BC Ranch, Incorporated, Tax Matters Partner, Petitioners-Appellants v. Commissioner of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

Filed August 11, 2017.

Attorney(s) appearing for the Case

Jeffrey Scott Levinger , Levinger, P.C., Val J. Albright , Gardere Wynne Sewell, L.L.P., Joseph Carl Cecere, Jr. , Attorney, Cecere, P.C., Dallas, TX, for Petitioners-Appellants.

Bethany Buck Hauser, Esq. , U.S. Department of Justice, Tax Division, Appellate Section, Robert R. DiTrolio , U.S. Tax Court, Kathryn Keneally , Gilbert Steven Rothenberg, Esq. , Senior Attorney, U.S. Department of Justice, Tax Division, U.S. Department of Justice, Tax Division, Appellate Section, William J. Wilkins , Internal Revenue Service, Washington, DC, for Respondent-Appellee.

George Asimos, Esq. , Saul Ewing, L.L.P., Harrisburg, PA, Harry Dean Shapiro, Esq. , Saul Ewing, L.L.P., Baltimore, MD, Amicus Curiae for NORTH AMERICAN LAND TRUST.

Before WIENER, DENNIS, and HAYNES, Circuit Judges.

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...

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