The Tax Court issued a decision and an opinion on Oakbrook Land Holdings.
Oakbrook Land Holdings, LLC v. Comm'r, 154 T.C. No. 10, (U.S.T.C. May. 12, 2020)
https://casetext.com/case/oakbrook-land ... lc-v-commr
which includes this:
In Oakbrook Land Holdings, LLC v. Commissioner, T.C. Memo. 2020-54, issued concurrently with this Opinion…
This discusses whether a particular regulation at issue is valid. This was an important part of the case, what the taxpayer was arguing, so I wonder why this is simply not part of the decision.
The decision is here
Oakbrook Land Holdings, LLC v. Comm'r, T.C. Memo. 2020-54, (U.S.T.C. May. 12, 2020)
https://casetext.com/case/oakbrook-land ... -v-commr-1
And includes this:
Our holding as to the meaning of section 1.170A-14(g)(6)(ii), Income Tax Regs., doesn't necessarily doom Oakbrook's deduction. Oakbrook argues in the alternative that this regulation is invalid. About this there is disagreement within the Court, and we air that disagreement in a separate opinion that we also release today
Again, why did the Court issue two separate items instead of one decision?