Charitable Contributions

A Deep Dive into Conservation Easements

Conservation Easements have caused quite a bit of a stir at the Tax Court in recent years.  Misunderstandings of the requirements and creativity (and greed) in drafting the easements has led to conservation easements earning a persona non grata status amongst the IRS and Tax Court judges, alike.  In this article, we examine the nuts and bolts of conservation easements and take you on a deep dive of the Code and Treasury Regulations related thereto. Introduction

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Scott St. Amand April 29, 2021
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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A Deep Dive into Conservation Easements

Conservation Easements have caused quite a bit of a stir at the Tax Court in recent years.  Misunderstandings of the requirements and creativity (and greed) in drafting the easements has led to conservation easements earning a persona non grata status amongst the IRS and Tax Court judges, alike.  In this article,

Read More »
Scott St. Amand April 29, 2021

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