Tax Court In Brief | Oxbow Bend, LLC v. Comm'r | Conservation Easement And "Initial Determination" Of Penalties

• Published date: 29 March 2022
• Law Firm: Freeman Law
• Author: Freeman Law

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Oxbow Bend, LLC v. Comm'r, T.C. Memo. 2022-23 | March 21, 2022?|Lauber, J. | Dkt. No. 12718-19

Short Summary: This case involves a charitable contribution deduction claimed by Oxbow Bend, LLC (Oxbow) for a conservation easement. In 2014, Oxbow owned interests in 133 acres and from those, Oxbow granted a conservation easement to an organization. For tax year 2014, Oxbow claimed charitable contribution deductions of near $17,000,000 combined for the donated easement and fee simple interest. The IRS examined Oxbow's 2014 Form 1065, U.S. Return of Partnership Income. During a call with Oxbow, the reviewing agent verbally explained the anticipated adjustments and penalties that were under consideration. Thereafter, the agent sent a her the notice of proposed adjustment...