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

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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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

Read More »
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 »

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 »

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 »