On March 17, 2022, the Tax Court issued a Memorandum Opinion in the case of Pickens Decorative Stone LLC v. Commissioner (T.C. Memo. 2022-22). The primary issues presented in Pickens Decorative Stone LLC v. Commissioner were (1) whether the taxpayer was entitled to qualified charitable contribution deduction for claimed easement, and (2) whether the IRS revenue agent secured timely supervisory approval from supervisor, as required for imposition of accuracy-related penalties due to substantial understatement of tax. Holding in Pickens Decorative Stone LLC v. Commissioner: The Tax Court denied the Motion for Summary Judgment on the IRC § 170(h)(5)(A) question but granted it with respect to IRC § 6751(b)(1). Background to Pickens Decorative Stone LLC v. Commissioner This is a syndicated conservation easement case. The IRS disallowed the charitable contribution deduction claimed for the easement by Pickens Decorative Stone LLC and determined penalties. In a motion for summary judgment, the IRS…