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 v. Commissioner 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

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Scott St. Amand March 3, 2021
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 Partners LLC v. Commissioner was whether Glade Creek is entitled to the easement deduction under the technical requirements of IRC § 170.

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Scott St. Amand November 2, 2020
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 v. Commissioner 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. Background to Dickinson v. Commissioner The petitioner-husband was the CFO and shareholder

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Scott St. Amand September 3, 2020
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 v. Commissioner 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

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Scott St. Amand June 23, 2020
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 v. Commissioner 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. Background to Donation in Brannan Sand & Gravel Co. LLC v.

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Scott St. Amand June 4, 2020
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 Land Holdings LLC v. Commissioner 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

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Scott St. Amand May 12, 2020
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 LLC 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 Land Holdings LLC v. Commissioner 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

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Scott St. Amand May 12, 2020
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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 v. Commissioner was whether the failure to attach appraisals can be due to reasonable cause when a taxpayer admits that he did not

Read More »
Scott St. Amand March 3, 2021

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 Partners LLC v. Commissioner was whether Glade Creek is entitled to the easement deduction under the technical requirements

Read More »
Scott St. Amand November 2, 2020

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 v. Commissioner was whether the IRS’s recharacterization of the petitioners’ stock donations as taxable redemptions followed by donations of the cash

Read More »
Scott St. Amand September 3, 2020

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 v. Commissioner was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of

Read More »
Scott St. Amand June 23, 2020

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 Land Holdings LLC

Read More »
Scott St. Amand May 12, 2020

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 LLC 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 Land Holdings LLC v.

Read More »
Scott St. Amand May 12, 2020