It was said that Billy T. Sherman came to hate that song, because he could not walk out his front door without some brass band playing it; legend has it that it was played at his funeral.

I don’t know Judge Kerrigan’s musical tastes, but today she has a duo of Effingham County conservation easements, sired by HRH, the progenitor of a large number of these dodges, and she gives both the Billy Sherman treatment.

The pair are Red Oak Estates, LLC, Amanda Farahany, Tax Matters Partner, 2020 T. C. Memo. 116, and  Cottonwood Place, LLC, Hugh F. Smisson, III, Tax Matters Partner, 2020 T. C. Memo. 115, both filed 8/4/20.

The issues are the usual, the split on extinguishment and the Chevron-Oakbrook joust over Reg. Section 1.170A-14(g)(6)(ii). Coal Holdings and PBBM each get a cameo appearance. And Belair comes up to tackle GA state law.

All the foregoing have furnished me with enough blogfodder, so that I need not unduly wear the reader’s patience by retelling an already-many-times-told tale. Just Google the case names.

In the end, Oakbrook carries the day. And now join in the chorus.