Tax Court Nixes Time-Bar Argument in Conservation Easement Case

The IRS issued a timely tax notice to a Kentucky partnership, the US Tax Court said Monday, rejecting Mammoth Cave Property LLC’s arguments that procedural errors invalidated the initial proposed notice and resulted in an expiration for the agency to make any adjustments.

A Notice of Final Partnership Adjustment issued to Mammoth Cave that disallowed a claimed charitable contribution deduction for 2018 was timely, Judge Kathleen Kerrigan wrote for the court. The IRS provided sufficient notice to the partnership through the notice of proposed partnership adjustment, or NOPPA, despite listing its former representative rather than its newly designated one and ...