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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International
Badaracco

Adams Challenge (UK) Limited v. Commissioner (156 T.C. No. 3)

On January 25, 2021, the Tax Court issued its opinion in Adams Challenge (UK) Limited v. Commissioner, 156 T.C. No. 3. The underlying issue presented in Adams Challenge (UK) Limited was whether the IRS erred in disallowing the petitioner’s deductions and credits and whether the IRS’s action violated the business profits and the nondiscrimination articles of the bilateral income tax treaty between the United States and the U.K. Background The petitioner is a U.K. corporation

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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 »

Adams Challenge (UK) Limited v. Commissioner (156 T.C. No. 3)

On January 25, 2021, the Tax Court issued its opinion in Adams Challenge (UK) Limited v. Commissioner, 156 T.C. No. 3. The underlying issue presented in Adams Challenge (UK) Limited was whether the IRS erred in disallowing the petitioner’s deductions and credits and whether the IRS’s action violated the business

Read More »