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COAL PROP. HOLDINGS, LLC v. COMMISSIONER

Docket No. 27778-16.

153 T.C. 126 (2019)

COAL PROPERTY HOLDINGS, LLC, COAL LAND MANAGER, LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 28, 2019.

Attorney(s) appearing for the Case

John P. Barrie, William G. Driggers, and Jerome A. Breed, for petitioner.

Sergio Garcia-Pages, Andrew M. Titkin, Michelle M. Robles, and Timothy A. Sloane, for respondent.

OPINION

In September 2013 Coal Property Holdings, LLC (Coal Holdings), acquired 3,713 acres of land in Tennessee that had been subject to surface mining during the last century. Three weeks later an entity owned by an investor acquired a 99% interest in Coal Holdings for $32.5 million. Three days later Coal Holdings donated...

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