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 Contributions

Plateau Holdings LLC v. Commissioner
T.C. Memo. 2020-93

On June 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Plateau Holdings LLC v. Commissioner (T.C. Memo. 2020-93). The primary issue before the court in Plateau Holdings LLC v. Commissioner 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

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Scott St. Amand June 23, 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
Charitable Contributions

Railroad Holdings LLC v. Commissioner
T.C. Memo. 2020-22

On February 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Railroad Holdings LLC v. Commissioner (T.C. Memo. 2020-22). The issue presented in Railroad Holdings LLC v. Commissioner was whether the extinguishment provisions contained in the grant of a conservation easement violated IRC § 170(h)(5)(A). Background to Railroad Holdings LLC v. Commissioner The petitioner executed a conservation easement deed in favor of a charitable organization. The deed provided that, if the easement

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Scott St. Amand February 5, 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

Plateau Holdings LLC v. Commissioner
T.C. Memo. 2020-93

On June 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Plateau Holdings LLC v. Commissioner (T.C. Memo. 2020-93). The primary issue before the court in Plateau Holdings LLC v. Commissioner was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of

Read More »
Scott St. Amand June 23, 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

Read More »
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

Read More »
Scott St. Amand April 17, 2020

Railroad Holdings LLC v. Commissioner
T.C. Memo. 2020-22

On February 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Railroad Holdings LLC v. Commissioner (T.C. Memo. 2020-22). The issue presented in Railroad Holdings LLC v. Commissioner was whether the extinguishment provisions contained in the grant of a conservation easement violated IRC § 170(h)(5)(A). Background to

Read More »
Scott St. Amand February 5, 2020