No. 22-323

Oakbrook Land Holdings, LLC, et al. v. Commissioner of Internal Revenue

Lower Court: Sixth Circuit
Docketed: 2022-10-06
Status: Denied
Type: Paid
Amici (4)
Tags: administrative-procedure-act charitable-donations conservation-easement conservation-easements income-tax-deductions judicial-review proceeds-regulation regulatory-process tax-deduction treasury-department
Key Terms:
AdministrativeLaw Environmental Arbitration Securities
Latest Conference: 2023-01-06
Question Presented (from Petition)

Whether Treasury's failure to respond to comments raising concerns about the Proceeds Regulation, 26 C.F.R. § 1.170A-14(g)(6)(ii), violated the Administrative Procedure Act?

Question Presented (AI Summary)

Whether Treasury's failure to respond to comments raising concerns about the Proceeds Regulation, 26 C.F.R. § 1.170A-14(g)(6)(i) violated the Administrative Procedure Act?

Docket Entries

2023-01-09
Motion for leave to file amicus brief filed by National Taxpayers Union Foundation GRANTED.
2023-01-09
Petition DENIED.
2022-12-21
DISTRIBUTED for Conference of 1/6/2023.
2022-12-12
Reply of petitioner Oakbrook Land Holdings, LLC, et al. filed.
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2022-12-07
Brief of respondent Commissioner of Internal Revenue in opposition filed.
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2022-11-07
Brief amicus curiae of Silicon Valley Tax Directors Group filed.
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2022-11-07
Motion for leave to file amicus brief filed by National Taxpayers Union Foundation.
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2022-11-02
Brief amicus curiae of GBX Group LLC filed.
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2022-10-26
Motion to extend the time to file a response is granted and the time is extended to and including December 7, 2022.
2022-10-25
Motion to extend the time to file a response from November 7, 2022 to December 7, 2022, submitted to The Clerk.
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2022-10-04
Petition for a writ of certiorari filed. (Response due November 7, 2022)
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Attorneys

Commissioner of Internal Revenue
Elizabeth B. Prelogar — Solicitor General, Respondent
GBX Group LLC
Katherine Schadler Jordan — GBX Group LLC, Amicus
National Taxpayers Union Foundation
Joseph Darcy Henchman — National Taxpayers Union Foundation, Amicus
Oakbrook Land Holdings, LLC, William Duane Horton, Tax Matters Partner
David William Foster — Skadden, Arps, Slate, Meagher & Flom LLP, Petitioner
Silicon Valley Tax Directors Group
David B. Salmons — Morgan, Lewis & Bockius LLP, Amicus