Case: Tax Reporting for Partnership Technical Termination Needed More Explanation, Partial Summary Judgment Denied (T.C.) (Former IRC §708)

Taxpayer, a partnership, and the IRS did not provide enough explanation on the tax reporting rules for partnership technical terminations in their posttrial briefing, the U.S. Tax Court held, denying both the IRS’s and Taxpayer’s motions for partial summary judgment. On Dec. 29, Taxpayer experienced a technical termination under former I.R.C. §708(b)(1)(B). Later that day, Taxpayer granted a conservation easement, for which it took a charitable contribution deduction on its short year return covering Dec. 29 through Dec. 31. The IRS argued that the deduction was claimed in the wrong tax year; the initial tax year closed on the technical ...