Morgan Run Partners, LLC, Overflow Marketing, LLC, Tax Matters Partner v. Comm'r, T.C. Memo. 2022-61 | June 14, 2022 | Lauber, J. | Docket No. 8669-20
Short Summary: Morgan Run Partners, LLC ("Morgan" or "Petitioner") petitioned the Tax Court for readjustment of partnership items after the IRS disallowed a deduction and assessed penalties. The IRS disallowed Morgan's charitable contribution deduction for a syndicated conservation easement, which it claimed on a timely Form 1065 and supported with an appraisal.
>Morgan granted to the National Farmer's Trust (the "Trust") a conservation easement over 232 acres of land. Petitioner timely filed a return and for 2016 and a deduction of $26 million for donation of the easement. The IRS then selected Morgan's return for an examination. The Revenue Agent (RA) recommended assessing penalties under IRC sections 6662 and 6662A. Her manager agreed and signed an approval form in September of 2019. In late October the RA mailed petitioner documents detailing the proposed adjustments and penalties. Then in January 2020, the IRS sent a notice of final partnership administrative adjustment (FPAA), including a Form 886-A, Explanation of Items.
Key Issues:
In a Motion for Summary Judgment, the IRS asked the Court to find that procedure was properly followed and attacked various aspects of...
