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
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
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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