Charitable Contributions

Montgomery-Alabama River, LLC v. Commissioner (T.C. Memo. 2021-62)

On May 17, 2021, the Tax Court issued a Memorandum Opinion in the case of Montgomery-Alabama River, LLC v. Commissioner (T.C. Memo. 2021-62). The primary issue presented in Montgomery-Alabama River was whether the Tax Court should certify (to the Alabama Supreme Court) the question of whether, under Alabama law, the petitioner would be entitled to the full proceeds of any sale if the easement were extinguished. Basic Legal Framework The governing regulation requires that the

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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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Conservation Easements

Kissling v. Commissioner (T.C. Memo. 2020-153)

On November 12, 2020, the Tax Court issued a Memorandum Opinion in the case Kissling v. Commissioner (T.C. Memo. 2020-153). The primary issue before the court in Kissling was how the Tax Court gauges the marginal effect of an easement in light of local law.

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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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Conservation Easements

Cottonwood Place, LLC v. Commissioner (T.C. Memo. 2020-115)

On August 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Cottonwood Place, LLC v. Commissioner (T.C. Memo. 2020-115). The primary issue before the court in Cottonwood Place 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 charitable

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Conservation Easements

Belair Woods, LLC v. Commissioner (T.C. Memo. 2020-112)

On July 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Belair Woods, LLC v. Commissioner (T.C. Memo. 2020-112). The primary issue before the court in Belair Woods 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 charitable

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Conservation Easements

Smith Lake, LLC v. Commissioner (T.C. Memo. 2020-107)

On July 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Smith Lake, LLC v. Commissioner (T.C. Memo. 2020-107). The primary issue before the court in Smith Lake, 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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Montgomery-Alabama River, LLC v. Commissioner (T.C. Memo. 2021-62)

On May 17, 2021, the Tax Court issued a Memorandum Opinion in the case of Montgomery-Alabama River, LLC v. Commissioner (T.C. Memo. 2021-62). The primary issue presented in Montgomery-Alabama River was whether the Tax Court should certify (to the Alabama Supreme Court) the question of whether, under Alabama law, the

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

Read More »

Kissling v. Commissioner (T.C. Memo. 2020-153)

On November 12, 2020, the Tax Court issued a Memorandum Opinion in the case Kissling v. Commissioner (T.C. Memo. 2020-153). The primary issue before the court in Kissling was how the Tax Court gauges the marginal effect of an easement in light of local law.

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 »

Cottonwood Place, LLC v. Commissioner (T.C. Memo. 2020-115)

On August 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Cottonwood Place, LLC v. Commissioner (T.C. Memo. 2020-115). The primary issue before the court in Cottonwood Place was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of a conservation

Read More »

Belair Woods, LLC v. Commissioner (T.C. Memo. 2020-112)

On July 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Belair Woods, LLC v. Commissioner (T.C. Memo. 2020-112). The primary issue before the court in Belair Woods was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of a conservation

Read More »

Smith Lake, LLC v. Commissioner (T.C. Memo. 2020-107)

On July 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Smith Lake, LLC v. Commissioner (T.C. Memo. 2020-107). The primary issue before the court in Smith Lake, LLC was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of a

Read More »