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IRBY v. COMMISSIONER

Docket Nos. 7559-10, 7561-10, 7562-10.

139 T.C. 371 (2012)

CHARLES R. IRBY AND IRENE IRBY, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE.

United States Tax Court.

Filed October 25, 2012.

Attorney(s) appearing for the Case

Larry D. Harvey, for petitioners.

Luke D. Ortner, Robert A. Varra, and Sara Jo Barkley, for respondent.

OPINION

JACOBS, Judge:

Charles Irby, Irene Irby, Dale Irby, and Stanley Irby (sometimes referred to as the Irbys or petitioners) are members of Irby Ranches, LLC, a Colorado limited liability company that elected to be taxed as a partnership for 2003 and 2004. As discussed in greater detail infra, Irby Ranches, LLC, conveyed to Colorado Open Lands, a "qualified organization" as defined in section 170(h)(3), two conservation easements: one in...

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