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Two Chip, LLC v. Comm'r of Internal Revenue

United States Tax Court
Mar 20, 2023
No. 19469-21 (U.S.T.C. Mar. 20, 2023)

Opinion

19469-21

03-20-2023

TWO CHIP, LLC, TWO CHIP INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Mark V. Holmes, Judge

This case was on the Court's October 24, 2022 trial calendar for Atlanta, Georgia. It is a syndicated conservation-contribution case with a twist, however, in that it features a donation not of an easement, but of a fee-simple interest. What, if any, effect this has on the transaction's being a "listed transaction" remains to be seen. The parties agreed that they'd like to try to settle it at IRS Appeals. The parties should have met with IRS Appeals by now, so it is

ORDERED that on or before May 8, 2023 the parties shall file a status report to describe their progress at IRS Appeals.


Summaries of

Two Chip, LLC v. Comm'r of Internal Revenue

United States Tax Court
Mar 20, 2023
No. 19469-21 (U.S.T.C. Mar. 20, 2023)
Case details for

Two Chip, LLC v. Comm'r of Internal Revenue

Case Details

Full title:TWO CHIP, LLC, TWO CHIP INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v…

Court:United States Tax Court

Date published: Mar 20, 2023

Citations

No. 19469-21 (U.S.T.C. Mar. 20, 2023)