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Plateau Holdings, LLC v. Comm'r of Internal Revenue

United States Tax Court
Aug 26, 2022
No. 12519-16 (U.S.T.C. Aug. 26, 2022)

Opinion

12519-16

08-26-2022

PLATEAU HOLDINGS, LLC, WATERFALL DEVELOPMENT MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER AND DECISION

Albert G. Lauber, Judge

On November 30, 2021, the Court issued an Opinion in this case (T.C. Memo. 2021-133), which states at the end thereof that "[decision will be entered under Rule 155." On August 25, 2022, the parties jointly filed a Computation for Entry of Decision under Rule 155. Upon due consideration, and consistently with the parties' computation, it is

ORDERED and DECIDED: That the following statement shows the adjustments to the partnership items of Plateau Holdings, LLC, for the tax period ending December 31, 2012:

Partnership Item

As Reported

As Determined

Charitable Contributions

$25,472,000

$23,000

That a 40 percent accuracy-related penalty for gross valuation misstatement under I.R.C. § 6662(a), (b)(3), (e) and (h) applies to the portion of any underpayment of tax attributable to claiming the charitable contribution deduction in excess of $2,714,200; and

That no penalty under I.R.C. § 6662(a) applies to the portion of any underpayment of tax attributable to claiming the charitable contribution deduction up to $2,714,200.


Summaries of

Plateau Holdings, LLC v. Comm'r of Internal Revenue

United States Tax Court
Aug 26, 2022
No. 12519-16 (U.S.T.C. Aug. 26, 2022)
Case details for

Plateau Holdings, LLC v. Comm'r of Internal Revenue

Case Details

Full title:PLATEAU HOLDINGS, LLC, WATERFALL DEVELOPMENT MANAGER, LLC, TAX MATTERS…

Court:United States Tax Court

Date published: Aug 26, 2022

Citations

No. 12519-16 (U.S.T.C. Aug. 26, 2022)