Champions Retreat Golf Founders, LLC v. Comm’r

BVLaw
Full Text of Court Cases
October 17, 2022
7992 Public Golf Courses
713910 Golf Courses and Country Clubs
federal taxation
business valuation, income approach, discount, fair market value (FMV), comparable

Champions Retreat Golf Founders, LLC v. Comm’r
T.C. Memo 2022-106; 2022 Tax Ct. Memo LEXIS 108
US
Federal Court
Federal
United States Tax Court
Claud Clark, III; Thomas F. Wingard; David G. Pope
Pugh

Summary

The Tax Court, on remand from the 11th Circuit, which decided that the taxpayer was entitled to a charitable donation for donation of a conservation easement, now valued that interest to determine the amount of the donation deduction. Both parties presented valuation opinions from expert appraisers. The Tax Court determined that the highest and best use of the property before and after the grant of the easement was the key to the determination of the value of the easement. The Tax Court then analyzed the evidence from the expert appraisals to arrive at a value of the easement.
Champions Retreat Golf Founders, LLC v. Comm'r
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See Also

On Remand, the Tax Court Determines the Value of a Conservation Easement From a Golf Course

The Tax Court, on remand from the 11th Circuit, which decided that the taxpayer was entitled to a charitable donation for donation of a conservation easement, now valued that interest to determine the amount of the donation deduction. Both parties presented valuation opinions from expert appraisers. The Tax Court determined that the highest and best use of the property before and after the grant of the easement was the key to the determination of the value of the easement. The Tax Court then analyzed the evidence from the expert appraisals to arrive at a value of the easement.