GREEN VALLEY INVESTORS, LLC, BOBBY A. BRANCH, TAX MATTERS PARTNER, ET. AL.,1 Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent, 2022 U.S. Tax Ct. LEXIS 702

Summary

HOLDINGS: [1]-In a tax case arising out of a petition challenging the IRS's notice of final partnership administrative adjustment (FPAA) determinations regarding charitable deductions related to syndicated conservation easement transactions, petitioner's motion for partial summary judgment on the issue of whether the IRS complied with 26 U.S.C.S. § 6751 when asserting penalties found in the FPAAs was denied because, based on the court's review of the declarations, the court determined that there were genuine disputes as to the material facts; [2]-Petitioner's motion for partial summary judgment to set aside Notice 2017-10 and prohibit the imposition of 26 U.S.C.S. § 6662A penalties as the IRS met the requirements of § 6751(b)(1) as to the § 6662A penalties.