A bunch Dixieland Boondockery opinions (hi, Judge Holmes), with no joy for the investors.

Vivian D. (“Golden”) Hoard, Esq., and her colleagues are still hunting the Section 6751(b) bubble in Jefferson Property Holdings, LLC, Strategic Fund Manager, LLC, Partnership Representative, T. C. Memo. 2025-75, filed 7/14/25, and Sand Valley Holdings, LLC, Sand Valley Investors, LLC, Tax Matters Partner, T. C. Memo. 2025-74, filed 7/14/25. Much of a muchness, supervisors signing off before they lose their supervisees, the fight over who made the initial determination, but at the end of the day, the cool second look that Congress wanted has been swamped by the sloppy drafting of a remedial statute. Judge Albert G. (“Scholar Al”) Lauber finds nothing new; citations are the usual suspects.

Judge Nega needs 55 (count ’em, 55) pages to deal with four (count ’em, four) consolidated cases, all with appraisal strikeouts. But even though the syndicated conservation easement deductions fail for want of competent appraisals, Judge Nega must decide if the substantial overvaluation chops that IRS wants to assess are warranted. So the defective appraisals are still at issue.

Spoiler alert!

IRS wins.