Opinion
12104-19
11-13-2024
NORTH BY NORTHWEST IV, LLC, BRYAN W. KELLEY, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
ELIZABETH CREWSON PARIS JUDGE
On September 3, 2024, docket entry 127, respondent filed a 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 lodged concurrently with his Motion be entered as the decision in this case.
After due consideration, it is
ORDERED that respondent's Motion for Entry of Decision, filed September 3, 2024, docket entry 127, is granted. It is further
ORDERED AND DECIDED: That the following statement shows the adjustments to the partnership items of North by Northwest IV, LLC, for the taxable period ending December 31, 2014:
| Partnership Item | As Reported | As Determined |
| Charitable contributions 50 percent - Schedule K, line 13a | $31,005,000 | $5,000 |
| Other Deduction - Schedule K, line 13d | $1,282,820 | $4,538,487 |
That a 10 percent accuracy-related penalty for gross valuation misstatement under I.R.C. § 6662(h) applies to any resulting underpayment of tax;
That no penalties pursuant to I.R.C. §§ 6662(b)(1), 6662(b)(2), or 6662(b)(3) apply to any underpayment of tax resulting from the above adjustments to partnership items for the taxable year ending December 31, 2014;
That no penalty pursuant to I.R.C. § 6662A applies to any understatement of tax resulting from the above adjustments to partnership items for the taxable year ending December 31, 2014;
That no penalty pursuant to I.R.C. § 6663 applies to any understatement of tax resulting from the above adjustments to partnership items for the taxable year ending December 31, 2014.