Tax Opinions

Lloyd v. Commissioner
T.C. Memo. 2020-92

On June 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Lloyd v. Commissioner (T.C. Memo. 2020-92). The issue before the court in Lloyd v. Commissioner was whether a taxpayer’s claims that “the income tax law is null and void” and that “he is entitled to a religious exemption from paying income tax because he is functioning as a church relieves him from the requirement to file and/or pay Federal income

Read More »
Scott St. Amand June 22, 2020
Tax Opinions

Brannan Sand & Gravel Co. LLC v. Commissioner
T.C. Memo. 2020-76

On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Brannan Sand & Gravel Co. LLC v. Commissioner (T.C. Memo. 2020-76). The issue before the court in Brannan Sand & Gravel Co. LLC v. Commissioner was whether the petitioner substantiated (as required by Treas. Reg. § 1.170A-13(c)) a $200,000 charitable contribution claimed for the donation of certain water storage rights. Background to Donation in Brannan Sand & Gravel Co. LLC v.

Read More »
Scott St. Amand June 4, 2020
Tax Opinions

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.

Read More »
Scott St. Amand May 13, 2020
Tax Opinions

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

Read More »
Scott St. Amand May 12, 2020
Tax Opinions

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

Read More »
Scott St. Amand May 12, 2020
Tax Opinions

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

Read More »
Scott St. Amand April 17, 2020
Charitable Issues

Campbell v. Commissioner
T.C. Memo. 2020-41

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Campbell v. Commissioner (T.C. Memo. 2020-41). The primary issue before the court in Campbell v. Commissioner was whether petitioners are entitled to a charitable contribution deduction with respect to donation, which hinges on the issues of whether the taxpayer submitted appropriate substantiation for the contribution and/or reasonably relied on the advice of a CPA that the charitable deduction was appropriate.

Read More »
Scott St. Amand April 7, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular posts:

Redefining Your Financial Outlook for Greater Life Success
Guest Post

Redefining Your Financial Outlook for Greater Life Success Guest Writer:  Michael Longsdon of ElderFreedom.net* It’s a powerful realization that our financial success is deeply intertwined with our money mindset. This article will guide you through the steps to rewire your perception of money and to redefine your financial outlook, opening

Read More »
Scott St. Amand November 28, 2023

Can an Estate’s Creditor Compel a Florida Personal Representative to Produce an Estate Tax Return in a Probate Proceeding?

In this article, we examine whether an estate’s creditor may compel a Florida personal representative to produce an estate tax return in a probate proceeding. On Hilda’s Passing & Packers’ Tickets When your Great-Aunt Hilda died, Uncle Bill was appointed as her co-personal representative along with Hilda’s long-time paramour, Wilhelm

Read More »
Scott St. Amand October 16, 2023

Ultimate Guide to Managing Business Finances for Entrepreneurs
Guest Post

Guest Writer:  Michael Longsdon of ElderFreedom.net* As an entrepreneur, managing the finances of your business can be a daunting task, which is why this Guide to Managing Business Finances for Entrepreneurs was created. It is not uncommon to feel overwhelmed, especially if you lack experience in finance. However, good financial

Read More »
Scott St. Amand June 26, 2023

Norberg v. Commissioner
T.C. Memo. 2022-30

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Norberg v. Commissioner (T.C. Memo. 2022-30). The primary issue presented in Norberg v. Commissioner was whether the settlement officer abused its discretion in upholding a notice of intent to levy and denying the petitioners’ request

Read More »
Scott St. Amand January 24, 2023

Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied;

Read More »
Scott St. Amand November 23, 2022

Middleton v. Commissioner
T.C. Memo. 2022-28

On April 4, 2022, the Tax Court issued a Memorandum Opinion in the case of Middleton v. Commissioner (T.C. Memo. 2022-28). The primary issues presented in Middleton v. Commissioner were (i) whether the taxpayer could challenge the Trust Fund Recovery Penalty at his CDP hearing; and (ii) whether the taxpayer

Read More »
Scott St. Amand November 22, 2022