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PINE MOUNTAIN PRESERVE LLLP v. COMMISSIONER

Docket No. 8956-13.

151 T.C. 247 (2018)

151 T.C. No. 14

PINE MOUNTAIN PRESERVE, LLLP F.K.A. CHELSEA PRESERVE, LLLP, EDDLEMAN PROPERTIES, LLC, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 27, 2018.

Attorney(s) appearing for the Case

David M. Wooldridge, Ronald Levitt, Gregory P. Rhodes, and Michelle A. Levin, for petitioner.

Edwin B. Cleverdon and Horace Crump, for respondent.

For the calendar taxable years 2005, 2006, and 2007, the Internal Revenue Service (IRS or respondent) issued notices of final partnership administrative adjustment (FPAAs) to Pine Mountain Preserve, LLLP. These notices disallowed charitable contribution deductions claimed by the partnership...

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