Opinion
7636-19
11-17-2021
Flomaton Pits, LLC, Big Escambia Ventures, LLC, Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Albert G. Lauber Judge.
This case involves a charitable contribution deduction claimed by Flomaton Pits, LLC, for a con - servation easement. Flomaton Pits is subject to the TEFRA unified audit and litigation procedures, and petitioner Big Escambia Ventures, LLC, is its tax matters partner (TMP). The TMP is the petitioner in 11 other cases that involve certain common issues of law and fact.
On July 21, 2021, respondent filed a Motion for Partial Summary Judgment asserting that the IRS secured timely supervisory approval for the penalties im posed in this case. On August 23, 2021, petitioner filed a response representing that it does not object to the granting of respondent's Motion. We will therefore grant the Motion. The disposition of this Motion has no effect on the 11 related cases, and petitioner remains free to challenge the merits of the penalties imposed in this case.
In consideration of the foregoing, it is
ORDERED that respondent's Motion for Partial Summary Judgment, filed July 21, 2021, is granted.