Charitable Contributions

Pankratz v. Commissioner (T.C. Memo. 2021-26)

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Pankratz v. Commissioner (T.C. Memo. 2021-26). The primary issue presented in Pankratz was whether the failure to attach appraisals can be due to reasonable cause when a taxpayer admits that he did not review his tax returns before filing. Introductory Notes: I cannot say for sure whether the return preparers were actually the fire chief and the village idiot, but

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Charitable Contributions

Glade Creek Partners LLC v. Commissioner (T.C. Memo. 2020-148)

On November 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Glade Creek Partners, LLC v. Commissioner (T.C. Memo. 2020-148). The primary issue before the court in Glade Creek was whether Glade Creek is entitled to the easement deduction under the technical requirements of IRC § 170.

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Charitable Contributions

Dickinson v. Commissioner (T.C. Memo. 2020-128)

On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Dickinson v. Commissioner (T.C. Memo. 2020-128). The primary issue before the court in Dickinson was whether the IRS’s recharacterization of the petitioners’ stock donations as taxable redemptions followed by donations of the cash proceeds was appropriate, or whether the form of the transaction should be respected.

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Charitable Contributions

Plateau Holdings LLC v. Commissioner (T.C. Memo. 2020-93)

On June 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Plateau Holdings, LLC v. Commissioner (T.C. Memo. 2020-93). The primary issue before the court in Plateau Holdings, LLC was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of a conservation easement in full because the conservation purpose underlying the easements was not “protected in perpetuity” as required by IRC § 170(h)(5)(A), insofar as the

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Charitable Contributions

Brannan Sand & Gravel Co. LLC v. Commissioner (T.C. Memo. 2020-76)

On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Brannan Sand & Gravel Co., LLC v. Commissioner (T.C. Memo. 2020-76). The issue before the court in Brannan Sand & Gravel Co., LLC was whether the petitioner substantiated (as required by Treas. Reg. § 1.170A-13(c)) a $200,000 charitable contribution claimed for the donation of certain water storage rights.

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Charitable Contributions

Oakbrook Land Holdings LLC v. Commissioner (T.C. Memo. 2020-54)

On May 12, 2020, the Tax Court issued its Memorandum Opinion in Oakbrook Land Holdings, LLC v. Commissioner, T.C. Memo. 2020-54 (Oakbrook I) concurrently with a full Tax Court opinion in Oakbrook Land Holdings v. Commissioner, 154 T.C. No. 10 (Oakbrook II). The issue presented in Oakbrook I was whether Oakbrook’s conservation easement violated the “protected in perpetuity” requirement of IRC § 170(h)(5), as interpreted in Treas. Reg. § 1.170A-14(g)(6), because the donee’s share of

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Charitable Contributions

Oakbrook Land Holdings LLC v. Commissioner (154 T.C. No. 10)

On May 12, 2020, the Tax Court issued its opinion in Oakbrook Land Holdings v. Commissioner, 154 T.C. No. 10 (Oakbrook I) and concurrently issued a Memorandum Opinion in Oakbrook Land Holdings, LLC v. Commissioner, T.C. Memo. 2020-54 (Oakbrook II). The issue presented in Oakbrook I was whether, for purposes of a conservation easement, the “protected in perpetuity” requirement of IRC § 170(h)(5), as interpreted in Treas. Reg. § 1.170A-14(g)(6), which was found to have

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Pankratz v. Commissioner (T.C. Memo. 2021-26)

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Pankratz v. Commissioner (T.C. Memo. 2021-26). The primary issue presented in Pankratz was whether the failure to attach appraisals can be due to reasonable cause when a taxpayer admits that he did not review his

Read More »

Glade Creek Partners LLC v. Commissioner (T.C. Memo. 2020-148)

On November 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Glade Creek Partners, LLC v. Commissioner (T.C. Memo. 2020-148). The primary issue before the court in Glade Creek was whether Glade Creek is entitled to the easement deduction under the technical requirements of IRC §

Read More »

Dickinson v. Commissioner (T.C. Memo. 2020-128)

On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Dickinson v. Commissioner (T.C. Memo. 2020-128). The primary issue before the court in Dickinson was whether the IRS’s recharacterization of the petitioners’ stock donations as taxable redemptions followed by donations of the cash proceeds was

Read More »

Plateau Holdings LLC v. Commissioner (T.C. Memo. 2020-93)

On June 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Plateau Holdings, LLC v. Commissioner (T.C. Memo. 2020-93). The primary issue before the court in Plateau Holdings, LLC was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of a

Read More »

Oakbrook Land Holdings LLC v. Commissioner (T.C. Memo. 2020-54)

On May 12, 2020, the Tax Court issued its Memorandum Opinion in Oakbrook Land Holdings, LLC v. Commissioner, T.C. Memo. 2020-54 (Oakbrook I) concurrently with a full Tax Court opinion in Oakbrook Land Holdings v. Commissioner, 154 T.C. No. 10 (Oakbrook II). The issue presented in Oakbrook I was whether

Read More »

Oakbrook Land Holdings LLC v. Commissioner (154 T.C. No. 10)

On May 12, 2020, the Tax Court issued its opinion in Oakbrook Land Holdings v. Commissioner, 154 T.C. No. 10 (Oakbrook I) and concurrently issued a Memorandum Opinion in Oakbrook Land Holdings, LLC v. Commissioner, T.C. Memo. 2020-54 (Oakbrook II). The issue presented in Oakbrook I was whether, for purposes

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