Conservation Easements

901 South Broadway Limited Partnership v. Commissioner
T.C. Memo. 2021-132

 On November 23, 2021, the Tax Court issued a Memorandum Opinion in the case of 901 South Broadway Limited Partnership v. Commissioner (T.C. Memo. 2021-132). The primary issue presented in 901 South Broadway Limited Partnership was whether a partnership’s gift to a qualified organization satisfied the requirement of IRC § 170(h)(5)(A) that the gift’s conservation purposes must be protected in perpetuity. Held: DO NOT GET CREATIVE WITH CONSERVATION EASEMENTS!!! Background to 901 South Broadway Limited

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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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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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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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Penalties Under the Code
Accuracy Related Penalty

Chiarelli v. Commissioner
T.C. Memo. 2021-27

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Chiarelli v. Commissioner (T.C. Memo. 2021-27). The primary issues presented in Chiarelli v. Commissioner were whether the petitioner was entitled to noncash charitable contribution deductions for the years at issue and whether the petitioner was liable for the IRC § 6662(a) accuracy-related penalties for 2012 and 2013. Incomplete Form 8283 in Chiarelli v. Commissioner The petitioner inherited valuable property from

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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 v. Commissioner 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 Partners LLC v. Commissioner was whether Glade Creek is entitled to the easement deduction under the technical requirements of IRC § 170.

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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 »

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 »

Chiarelli v. Commissioner
T.C. Memo. 2021-27

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Chiarelli v. Commissioner (T.C. Memo. 2021-27). The primary issues presented in Chiarelli v. Commissioner were whether the petitioner was entitled to noncash charitable contribution deductions for the years at issue and whether the petitioner was

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 v. Commissioner 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 Partners LLC v. Commissioner was whether Glade Creek is entitled to the easement deduction under the technical requirements

Read More »