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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Scott St. Amand November 2, 2020
Charitable Contribution

Emanouil v. Commissioner
T.C. Memo. 2020-120

On August 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Emanouil v. Commissioner (T.C. Memo. 2020-120). The primary issues before the court in Emanouil v. Commissioner were (1) whether the petitioners complied with the qualified appraisal requirements of IRC § 170(f)(11)(C); (2) whether the petitioners contributions were part of a quid pro quo exchange rather than a charitable gift; (3) what the fair market values were of the properties that

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Scott St. Amand August 17, 2020
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 v. Commissioner 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. Background to Donation in Brannan Sand & Gravel Co. LLC v.

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Scott St. Amand June 4, 2020
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 v. Commissioner 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.

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Scott St. Amand May 13, 2020
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 Land Holdings LLC v. Commissioner 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

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Scott St. Amand May 12, 2020
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
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 v. Commissioner 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. Background to Hewitt

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Scott St. Amand April 17, 2020
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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 »
Scott St. Amand November 2, 2020

Emanouil v. Commissioner
T.C. Memo. 2020-120

On August 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Emanouil v. Commissioner (T.C. Memo. 2020-120). The primary issues before the court in Emanouil v. Commissioner were (1) whether the petitioners complied with the qualified appraisal requirements of IRC § 170(f)(11)(C); (2) whether the petitioners

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Scott St. Amand August 17, 2020

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 v. Commissioner was whether the conservation purpose underlying the easement is not “protected in perpetuity,” as

Read More »
Scott St. Amand May 13, 2020

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 Land Holdings LLC

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Scott St. Amand May 12, 2020

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

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 v. Commissioner was whether the petitioners are entitled to carryover of the charitable contribution deduction for the donation of a conservation

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Scott St. Amand April 17, 2020