Taxing, Briefly
Charitable Issues

Charitable Contributions – Part Two: Other Considerations

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, we will dig a little bit deeper and look at some issues that might affect the deductibility of a contribution. The Green Settee As we discussed in the first article,

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Taxing, Briefly
Charitable Issues

Charitable Contributions – Part One: 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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Tax Articles

A Deep Dive into Conservation Easements

If a taxpayer makes a charitable contribution of property other than money, the amount of the contribution is generally equal to the FMV of the property at the time the gift is made.[1] However, the Code restricts a taxpayer’s charitable contribution deduction for the donation of an interest in property that consists of less than the taxpayer’s entire interest in such property.[2] There is an exception to this entire interest rule for a “qualified conservation

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Tax Articles

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.  Although you are not unaccustomed to his unannounced visits, they are nevertheless jarring at 7:15 on a Tuesday morning.  Aunt Ethel explained that Bill has become more nocturnal in his advancing age, and, as such, he is not, technically, day drinking – at least not in his personal

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Tax Articles

Are you DEFRA (Compliant)?

The deductibility of a charitable contribution depends on the donor-taxpayer meeting several conditions, which conditions are determined by the size and type of contribution.  The larger the contribution, the more stringent the documentation and substantiation that is needed.[1]  With respect to non-cash donations, the amount of the contribution is generally equal to the fair market value of the property at the time of contribution.[2] Determining the FMV, however, is the factor that taxpayers so often

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Tax Articles

Peyote is not a Sacrament and Other Lessons on Religious Non-Exemptions

You can fault Jedediah for many things—many things—but charisma is not amongst them. It turns out that Jed has developed something of a following. He assures you that it is not a cult, which you have to imagine are the first words out of every cult leader’s mouth when questioned about it. Having drank Jed’s Kool-Aid, the members of his new religious “order” follow him around like willing lambs, but they have made musings about

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Tax Articles

Medical Marijuana Charity will be Denied § 501(c)(3) Exemption

Uncle Bill is a child of the Sixties. He is told you the story many a time how the lead singer for the Zombies stole his Beatle boots when they played at Old Orchard Beach the summer when he was 17. As Bill describes it, he was a “pharmaceutical rep” in college, which, you have to admit, is the classiest way of admitting that someone was a drug dealer that you’ve ever heard. It’s safe

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The Truth about Amending Tax Returns

Clients are untrustworthy.  As a tax controversy attorney, this is my experience. I have heard that other types of law deals with more honorable sorts, but I’ll believe it when I see it.  When a client comes to you and says “whoopsie, I forgot to report [insert absurdly large number

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Mathews v. Commissioner (T.C. Memo. 2021-85)

On July 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-85). The primary issue presented in Mathews was whether the Tax Court had jurisdiction to hear a petitioner when the pro se petitioner filed his petition (sent a letter to

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Delgado v. Commissioner (T.C. Memo. 2021-84)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Delgado v. Commissioner (T.C. Memo. 2021-84). The primary issue presented in Delgado was whether the petitioner’s frivolous argument that he did not receive taxable income in 2017 because he was not engaged in a “trade

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Peterfreund v. Commissioner (T.C. Memo. 2021-83)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Peterfreund v. Commissioner (T.C. Memo. 2021-83). The primary issue presented in Peterfreund was whether the IRS’s Whistleblower Office (WBO) abused its discretion because it did not initiate an administrative or judicial action and it did

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Pragias v. Commissioner (T.C. Memo. 2021-82)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Pragias v. Commissioner (T.C. Memo. 2021-82). The primary issue presented in Pragias was whether the six-year statute of limitations under IRC § 6501(e) (substantial omission of items) applied. The Substantial Omission Extension under IRC §

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