Taxing, Briefly
Charitable Contribution

Moving Beyond the Basics of Charitable Contributions

In our previous post, we took a high level look at charitable contributions and deductions, including looking at what made an organization “qualified” to receive charitable contributions, when deductions might be limited, and special rules for valuing and reporting non-cash charitable contributions. In this post, “Beyond the Basics of Charitable Contributions,” we will dig a little bit deeper and look at some issues that might affect the deductibility of a contribution. Moving Beyond the Basics

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Scott St. Amand July 5, 2021
Taxing, Briefly
Charitable Contributions

Basic Concepts for Charitable Deductions

Your grandmother Phyllis was a remarkable woman. Aside from making it out on the other side of Uncle Bill’s childhood with only moderate shell shock (which, I suppose, is referred to these days as PTSD), Phyllis was an intelligence agent in the United States Army towards the end of World War II, and you could remember her saying that, despite as “intelligent” as she may have been in the Army’s estimation, her good genes weren’t

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Scott St. Amand July 5, 2021
Aunt Ethel

Deducting Charitable Contributions from a Trust that Does not Permit Charitable Contributions

Uncle Bill comes to your office in a bit of a tizzy with two beers in one hand and three notices from the IRS in the other.  Unbeknownst to you, he wants to discuss deducting charitable contributions from a trust that doesn’t, technically, permit charitable contributions.  Although you are not unaccustomed to his unannounced visits, they are nevertheless jarring at 7:15 on a Tuesday morning. You note that Aunt Ethel recently explained that Bill has

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Scott St. Amand April 29, 2021
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 Contribution

Emanouil v. Commissioner
T.C. Memo. 2020-120

On August 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Emanouil v. Commissioner (T.C. Memo. 2020-120). The primary issues before the court in Emanouil v. Commissioner were (1) whether the petitioners complied with the qualified appraisal requirements of IRC § 170(f)(11)(C); (2) whether the petitioners contributions were part of a quid pro quo exchange rather than a charitable gift; (3) what the fair market values were of the properties that

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Scott St. Amand August 17, 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 Contribution

Woodland Property Holdings LLC v. Commissioner
T.C. Memo. 2020-55

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Woodland Property Holdings LLC v. Commissioner (T.C. Memo. 2020-55). The basic issue before the court in Woodland Property Holdings LLC v. Commissioner was whether the conservation purpose underlying the easement is not “protected in perpetuity,” as required by IRC § 170(h)(5)(A) and Treas. Reg. § 1.170A-14(g)(6). The same question was presented and resolved in Railroad Holdings, LLC v. Commissioner, T.C. Memo.

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Scott St. Amand May 13, 2020
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Moving Beyond the Basics of Charitable Contributions

In our previous post, we took a high level look at charitable contributions and deductions, including looking at what made an organization “qualified” to receive charitable contributions, when deductions might be limited, and special rules for valuing and reporting non-cash charitable contributions. In this post, “Beyond the Basics of Charitable

Read More »
Scott St. Amand July 5, 2021

Basic Concepts for Charitable Deductions

Your grandmother Phyllis was a remarkable woman. Aside from making it out on the other side of Uncle Bill’s childhood with only moderate shell shock (which, I suppose, is referred to these days as PTSD), Phyllis was an intelligence agent in the United States Army towards the end of World

Read More »
Scott St. Amand July 5, 2021

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

Emanouil v. Commissioner
T.C. Memo. 2020-120

On August 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Emanouil v. Commissioner (T.C. Memo. 2020-120). The primary issues before the court in Emanouil v. Commissioner were (1) whether the petitioners complied with the qualified appraisal requirements of IRC § 170(f)(11)(C); (2) whether the petitioners

Read More »
Scott St. Amand August 17, 2020

Woodland Property Holdings LLC v. Commissioner
T.C. Memo. 2020-55

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Woodland Property Holdings LLC v. Commissioner (T.C. Memo. 2020-55). The basic issue before the court in Woodland Property Holdings LLC v. Commissioner was whether the conservation purpose underlying the easement is not “protected in perpetuity,” as

Read More »
Scott St. Amand May 13, 2020