Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s)

Summary

The court determined that the conservation easement was worth $800,000 because the property had a $1,440,000 before value and a stipulated $640,000 after value. It held that the partnership improperly allocated the charitable-contribution deductions because the allocations did not reflect the partners who held interests when the contributions occurred. The court also upheld a 40% gross valuation-misstatement penalty, rejected the Seventh Amendment challenge, and held that the adequate-disclosure exception applies only to substantial-understatement penalties, not valuation-misstatement penalties.