Opinion
12154-23
07-12-2024
ANDERSON HOLLOW, LLC, BLACKLAND GROUP, LLC, PARTNERSHIP REPRESENTATIVE, Petitioner(s) v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Kathleen Kerrigan, Chief Judge
Because the Proposed Stipulated Decision, filed July 1, 2024, does not comply with Rule 23(a)(4) of the Tax Court Rules of Practice and Procedure, it is
ORDERED that the document is recharacterized and treated as a Stipulation of Settlement. To give effect to the basis of settlement reflected in that document, it is further
ORDERED AND DECIDED that the following statement shows the adjustment to the partnership-related items of Anderson Hollow, LLC, for the taxable year ending December 31, 2018:
Partnership-Related Item
As Reported
As Determined
Charitable contributions 50 percent -Schedule K, line 13a
$ 18,500,000
$ 0
Schedule K, line 13a It is determined that the above adjustment results in an imputed underpayment of $6,845,000.00.
It is determined that a 10 percent accuracy-related penalty for gross valuation misstatement under I.R.C. § 6662(h) applies to any resulting underpayment of tax.
It is determined that no accuracy-related penalties pursuant to I.R.C. §§ 6662A, 6662(d), 6662(c) and 6662(e) apply to any underpayment of tax resulting from the above adjustments to partnership items for the taxable year ending December 31, 2018.
It is determined that the following statement shows the adjustments to the partnership-related items of Anderson Hollow, LLC, for the 2018 tax year that do not result in an imputed underpayment:
Partnership-Related Item
As Reported
As Determined
Other Deduction - Schedule K, Line 13(d)
$ 60,761
$ 4,078,761