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SAND INV. CO., LLC v. COMMISSIONER

Docket No. 7307-19.

157 T.C. 136 (2021)

157 T.C. No. 11

SAND INVESTMENT CO., LLC, INLAND CAPITAL MANAGEMENT, LLC, TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 23, 2021.

Attorney(s) appearing for the Case

Hale E. Sheppard, Jeffrey S. Luechtefeld, John W. Hackney, Brent N. Bartlett, Samuel H. Grier, and Cassandra S. Bradford, for petitioner.

Timothy A. Sloane, Derek P. Richman, and Michelle M. Robles, for respondent.

OPINION

This case involves a charitable contribution deduction claimed by Sand Investment Co., LLC (Sand), for a conservation easement. The Internal Revenue Service (IRS or respondent) issued petitioner a notice of final partnership administrative adjustment (FPAA) disallowing Sand's deduction and determining accuracy-related...

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