Charitable Contributions

Brannan Sand & Gravel Co. LLC v. Commissioner (T.C. Memo. 2020-76)

On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Brannan Sand & Gravel Co., LLC v. Commissioner (T.C. Memo. 2020-76). The issue before the court in Brannan Sand & Gravel Co., LLC was whether the petitioner substantiated (as required by Treas. Reg. § 1.170A-13(c)) a $200,000 charitable contribution claimed for the donation of certain water storage rights.

Read More »
Charitable Contribution

Woodland Property Holdings LLC v. Commissioner (T.C. Memo. 2020-55)

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Woodland Property Holdings, LLC v. Commissioner (T.C. Memo. 2020-55). The basic issue before the court in Woodland Property Holdings, LLC was whether the conservation purpose underlying the easement is not “protected in perpetuity,” as required by IRC § 170(h)(5)(A) and Treas. Reg. § 1.170A-14(g)(6). The same question was presented and resolved in Railroad Holdings, LLC v. Commissioner, T.C. Memo. 2020-22

Read More »
Charitable Contributions

Oakbrook Land Holdings LLC v. Commissioner (T.C. Memo. 2020-54)

On May 12, 2020, the Tax Court issued its Memorandum Opinion in Oakbrook Land Holdings, LLC v. Commissioner, T.C. Memo. 2020-54 (Oakbrook I) concurrently with a full Tax Court opinion in Oakbrook Land Holdings v. Commissioner, 154 T.C. No. 10 (Oakbrook II). The issue presented in Oakbrook I was whether Oakbrook’s conservation easement violated the “protected in perpetuity” requirement of IRC § 170(h)(5), as interpreted in Treas. Reg. § 1.170A-14(g)(6), because the donee’s share of

Read More »
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

Read More »
Charitable Contribution

Hewitt v. Commissioner (T.C. Memo. 2020-89)

On June 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Hewitt v. Commissioner (T.C. Memo. 2020-89). The primary issue before the court in Hewitt was whether the petitioners are entitled to carryover of the charitable contribution deduction for the donation of a conservation easement, which, not unsurprisingly, depends on whether the conservation easement satisfies the perpetuity requirement in IRC § 170(h)(5) and accompanying Treasury Regulations.

Read More »
Bad Advice

Campbell v. Commissioner (T.C. Memo. 2020-41)

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Campbell v. Commissioner (T.C. Memo. 2020-41). The primary issue before the court in Campbell was whether petitioners are entitled to a charitable contribution deduction with respect to donation, which hinges on the issues of whether the taxpayer submitted appropriate substantiation for the contribution and/or reasonably relied on the advice of a CPA that the charitable deduction was appropriate.

Read More »
Charitable Contributions

Oakhill Woods LLC v. Commissioner (T.C. Memo. 2020-24)

On February 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Oakhill Woods, LLC v. Commissioner (T.C. Memo. 2020-24). The issues presented in Oakhill Woods, LLC were whether the petitioner satisfied for this donation the substantiation requirements of Treas. Reg. § 1.170A-13(c), and if it did not, whether Treas. Reg. § 1.170A-13(c) is, itself, invalid.

Read More »
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Woodland Property Holdings LLC v. Commissioner (T.C. Memo. 2020-55)

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Woodland Property Holdings, LLC v. Commissioner (T.C. Memo. 2020-55). The basic issue before the court in Woodland Property Holdings, LLC was whether the conservation purpose underlying the easement is not “protected in perpetuity,” as required

Read More »

Oakbrook Land Holdings LLC v. Commissioner (T.C. Memo. 2020-54)

On May 12, 2020, the Tax Court issued its Memorandum Opinion in Oakbrook Land Holdings, LLC v. Commissioner, T.C. Memo. 2020-54 (Oakbrook I) concurrently with a full Tax Court opinion in Oakbrook Land Holdings v. Commissioner, 154 T.C. No. 10 (Oakbrook II). The issue presented in Oakbrook I was whether

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 »

Hewitt v. Commissioner (T.C. Memo. 2020-89)

On June 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Hewitt v. Commissioner (T.C. Memo. 2020-89). The primary issue before the court in Hewitt was whether the petitioners are entitled to carryover of the charitable contribution deduction for the donation of a conservation easement, which,

Read More »

Campbell v. Commissioner (T.C. Memo. 2020-41)

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Campbell v. Commissioner (T.C. Memo. 2020-41). The primary issue before the court in Campbell was whether petitioners are entitled to a charitable contribution deduction with respect to donation, which hinges on the issues of whether

Read More »

Oakhill Woods LLC v. Commissioner (T.C. Memo. 2020-24)

On February 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Oakhill Woods, LLC v. Commissioner (T.C. Memo. 2020-24). The issues presented in Oakhill Woods, LLC were whether the petitioner satisfied for this donation the substantiation requirements of Treas. Reg. § 1.170A-13(c), and if it did

Read More »