Battelle Glover Invs. v. Comm'r of Internal Revenue

Full title: BATTELLE GLOVER INVESTMENTS, LLC, BATTELLE INVESTMENT GROUP, LLC, TAX…

Court: United States Tax Court

Date published: Mar 11, 2024

No. 6904-19 (U.S.T.C. Mar. 11, 2024)

Opinion

6904-19

03-11-2024

BATTELLE GLOVER INVESTMENTS, LLC, BATTELLE INVESTMENT GROUP, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Courtney D. Jones Judge

ORDER

Courtney D. Jones Judge

As to the stipulation of jurisdictional facts, the Court believes that providing

. the date of the FPAA with a copy attached as a joint exhibit; . a stipulation that the taxpayer timely filed the Petition; . a stipulation as to the identity of the Tax Matters Partner;

. a stipulation as to the amount of the claimed deduction;

. whether Form 8283 was attached to the return, and if so, a copy of the

Form 8283 attached as a joint exhibit;

. the recognition letter from the donee organization, attached as a joint

. a copy of the deed of conservation easement, attached as a joint exhibit;

. a copy of the baseline documentation report, if there is one, attached as a joint exhibit;

. any reports about the property, attached as joint exhibits;

. any private placement memoranda related to the transaction, attached Upon due consideration of the parties' Status Report filed March 5, 2024, it is

trial. In preparing the status report the parties shall advise the Court as to whether there are any current or anticipated discovery disputes. They shall likewise bear in mind the likelihood that the Court will hold partial trial on only the issue of valuation, with subsequent trial to follow only if necessary.