Tax Opinions

The Korean American Senior Mutual Assoc. Inc. v. Commissioner
T.C. Memo. 2020-129

On September 9, 2020, the Tax Court issued a Memorandum Opinion in the case of The Korean American Senior Mutual Assoc. Inc. v. Commissioner (T.C. Memo. 2020-129). The primary issue before the court in Korean-American was whether The Korean-American Senior Mutual Association, Inc. (KASMA) was operated exclusively for one or more exempt purposes as set forth in IRC § 501(c)(3). Background to The Korean American Senior Mutual Assoc. Inc. v. Commissioner The Korean-American Senior Mutual

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Scott St. Amand September 9, 2020
Tax Opinions

Dickinson v. Commissioner
T.C. Memo. 2020-128

On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Dickinson v. Commissioner (T.C. Memo. 2020-128). The primary issue before the court in Dickinson v. Commissioner was whether the IRS’s recharacterization of the petitioners’ stock donations as taxable redemptions followed by donations of the cash proceeds was appropriate, or whether the form of the transaction should be respected. Background to Dickinson v. Commissioner The petitioner-husband was the CFO and shareholder

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Scott St. Amand September 3, 2020
Tax Opinions

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
Tax Opinions

Red Oak Estates LLC v. Commissioner
T.C. Memo. 2020-116

On August 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Red Oak Estates LLC v. Commissioner (T.C. Memo. 2020-116). The primary issue before the court in Red Oak Estates 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),

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Scott St. Amand August 4, 2020
Memorandum Opinions

Cottonwood Place LLC v. Commissioner
T.C. Memo. 2020-115

On August 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Cottonwood Place LLC v. Commissioner (T.C. Memo. 2020-115). The primary issue before the court in Cottonwood Place 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 August 4, 2020
Tax Opinions

Belair Woods LLC v. Commissioner
T.C. Memo. 2020-112

On July 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Belair Woods LLC v. Commissioner (T.C. Memo. 2020-112). The primary issue before the court in Belair Woods 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 July 22, 2020
Tax Opinions

Smith Lake LLC v. Commissioner
T.C. Memo. 2020-107

On July 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Smith Lake LLC v. Commissioner (T.C. Memo. 2020-107). The primary issue before the court in Smith Lake 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 July 13, 2020
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