Opinion
19469-21
07-05-2023
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 recently reported good progress toward what might be a settlement. They reasonable request reporting back at the end of summer if they haven't settled, so it is
ORDERED that on or before August 31, 2023 the parties shall submit settlement documents or file a status report to describe their progress.