Judge Travis A. (“Tag”) Greaves, master of discovery, marries the 1982 Mel Gibson – Sigourney Weaver romadrama to Reg. Section 1.170A-13(c)(5)(iv)(F) in Carters Lake Land, LLC, f.k.a. Sassafras Point II, LLC, Piedmont Private Equity Manager, LLC, Tax Matters Partner, et al., Docket No. 1034-21, filed 7/2/25, lead case in a consolidated Dixieland Boondockery.

IRS served a blockbuster subpoena duces tecum (paper, not person) on appraisal firm Integrity, claiming their employee, whom I’ll call DM, wasn’t a qualified appraiser.

IRS wanted documents for years immediately prior to acquisition, acquisition, easement granted, and easement reported. Integrity claims this involves tons of documents, all of which its trusty attorneys need to scan for privilege and relevance, even after IRS offers a couple restrictive search terms (hi, Judge Holmes).

Integrity is down with providing documents relating to the three (count ’em, three) consolidated petitioners.

“Details regarding DM’s appraisal work, the clients he served, and Integrity’s relationship to petitioners are relevant to the issue of whether DM meets the definition of a qualified appraiser under section 170(f)(11)(E). This Court will allow respondent some latitude in its investigation to establish the relationship between petitioners and Integrity, ensuring the development of comprehensive legal arguments. The value and need for this information weigh against the motion to quash.” Order, at p. 5.

Except.

“Respondent’s request implicates potentially privileged information over a period of nearly four years. We disagree with respondent that such an extensive period is needed to determine whether someone is a qualified appraiser. Treas. Reg. section 1.170A-13(c)(5)(iv)(F) provides the relevant period — “the taxable year”. We will limit the temporal reach of the subpoena to the taxable year at issue. Integrity shall provide the relevant documentation for [taxable year at issue].” Order, at p. 6.

For the checklist for qualification and disqualification of an appraiser for Section 170 charitable giving, see Order, at p. 5.