Tax Opinions

Englewood Place LLC v. Commissioner
T.C. Memo. 2020-105

On July 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Englewood Place LLC v. Commissioner (T.C. Memo. 2020-105). The primary issue before the court in Englewood 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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Tax Opinions

Maple Landing LLC v. Commissioner (T.C. Memo. 2020-104)

On July 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Maple Landing LLC v. Commissioner (T.C. Memo. 2020-104). The primary issue before the court in Maple Landing 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

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Tax Opinions

Riverside Place LLC v. Commissioner (T.C. Memo. 2020-103)

On July 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Riverside Place LLC v. Commissioner (T.C. Memo. 2020-103). The primary issue before the court in Riverside 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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Tax Opinions

Village at Effingham LLC v. Commissioner
T.C. Memo. 2020-102

On July 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Village at Effingham LLC v. Commissioner (T.C. Memo. 2020-102). The primary issue before the court in Village at Effingham 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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Memorandum Opinions

Lumpkin HC LLC v. Commissioner
T.C. Memo. 2020-95

On June 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Lumpkin HC LLC v. Commissioner (T.C. Memo. 2020-95). The primary issue before the court in Lumpkin HC 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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Tax Opinions

Lumpkin One Five Six LLC v. Commissioner
T.C. Memo. 2020-94

On June 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Lumpkin One Five Six LLC v. Commissioner (T.C. Memo. 2020-94). The primary issue before the court in Lumpkin One Five Six 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

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Tax Opinions

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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