Opinion
29610-21
09-11-2024
MORTON BEND FARMS, LLC,RICHARD LINDSEY,TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Cary Douglas Pugh Judge
On July 3, 2024, respondent filed an unopposed Motion for Entry of Decision requesting, pursuant to Rule 248(b) of the Tax Court's Rules of Practice and Procedure, that the decision document respondent attached to the motion be entered as the decision in this case. The 60-day waiting period under Rule 248(b) has now expired, and no nonparticipating partner has moved for leave to intervene or participate in this case. Upon due consideration and for cause, it is hereby
ORDERED that respondent's Motion for Entry of Decision, filed July 3, 2024, is granted. It is further
ORDERED AND DECIDED: That the following statement shows the adjustments to the partnership items of Morton Bend Farms, LLC, for the taxable period ending December 31, 2017:
Partnership Item
As Reported
As Determined
Charitable contributions 50 percent - Schedule K, line 13a
$13,730,000
$30,000
Other Deduction - Schedule K, line 13(d)
$0
$2,206,375
Other Deduction - Form 1065, Line 20
$71,396
$0
That a 10 percent accuracy-related penalty for gross valuation misstatement under I.R.C. § 6662(h) applies to any resulting underpayment of tax;
No penalties pursuant to I.R.C. §§ 6662A, 6662(c), (d), or (e), apply to any underpayment of tax resulting from the above adjustments to partnership items for the taxable year ending December 31, 2017.