Attorney-at-Law

HOLD THE SWISS CHEESE

In Uncategorized on 11/13/2020 at 13:11

Wasting readers’ time (few though my readers may be, and short though everyone’s time when trying to make a living, even pre-COVID19; now, don’t ask) with speculation isn’t my thing. I’ll invest fact, even though less remunerative than conjecture.

Today, Friday the Thirteenth, I’ll break my rule. Looks like Judge Christian N. (“Speedy”) Weiler has another Jawjuh conservatorium, Longwood Preserve Holdings, LLC, Longwood Preserve Investors, LLC, Tax Matters Partner, Docket No. 12421-19, filed 11/13/20. And they’ve gotten to the summary J stage, so it might could be maybe so that Swiss cheese is on the cards.

For the Swiss cheese take-out, see my blogpost “Perpetually Swiss,” 12/27/18.

But the Longwoods want a stay of proceedings, to which IRS objects. Judge Speedy Weiler doesn’t tell us why IRS objects, but maybe the grounds on which the Longwoods seek same might enlighten us.

They want the stay pending the appeal in Hewitt.

All y’all will recollect that Dave Hewitt saved his Daddy’s farm from the mobile homemakers (those who develop trailer parks, not itinerant household managers) with a syndicated conservation easement that blew up on Swiss cheesery (Dave left five homesites for his kids, locations to be determined later), with extinguishment coming up fast, but was saved from the 40% chop by Dave’s cool appraisers. If not, see my blogpost “Gude Faith, He Maunna’ Fa’ That – Part Deux,” 6/17/20.

Dave later turned Daddy’s farm’s salvation into a cottage industry, but Judge Goeke left that for another day.

Well, the Elevenses just hammered IRS’ Swiss cheesery argument in Pine Moutain [sic] Preserve, LLLP, f.k.a. Chelsea Preserve, LLLP, F Eddleman Properties, LLC, Tax Matters Partner, No. 19-11795, 10/22/20. Read Judge Newsom’s hammer-job, but forgive the typo in the caption: should be “Mountain,” Elevenses proofreader.

And Dave’s appeal, filed 9/30/20, is bound for the Elevenses.

I’ll wager IRS would sooner have a collective root canal than another Elevenses’ hammering. And so would the Tax Court Bench.

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