Tax Opinions

Oakhill Woods LLC v. Commissioner (T.C. Memo. 2020-24)

On February 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Oakhill Woods, LLC v. Commissioner (T.C. Memo. 2020-24). The issues presented in Oakhill Woods, LLC were whether the petitioner satisfied for this donation the substantiation requirements of Treas. Reg. § 1.170A-13(c), and if it did not, whether Treas. Reg. § 1.170A-13(c) is, itself, invalid.

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Scott St. Amand February 13, 2020
Tax Opinions

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
Penalties Under the Code
Tax Opinions

Carter v. Commissioner
T.C. Memo. 2020-21

On February 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Carter v. Commissioner (T.C. Memo. 2020-20). The issues presented in Carter v. Commissioner were whether the restrictions contained in a conservation easement violated IRC § 170(h) and whether the IRS had satisfied the prior written supervisory approval requirement of IRC § 6751(b)(1). Background to Carter v. Commissioner The petitioners, through their partnership, conveyed an easement to NALT, a “qualified organization”

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Scott St. Amand February 3, 2020
Tax Opinions

Loube v. Commissioner
T.C. Memo. 2020-3

On January 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Loube v. Commissioner (T.C. Memo. 2020-3). The issues presented in Loube v. Commissioner were whether the petitioners had complied with § 155 of the Deficit Reduction Act of 1984 (DEFRA) with respect to the appraisal that they obtained regarding charitable deductions claimed on their return; and if not, whether the petitioners were in substantial compliance with DEFRA. Charitable Contributions, Generally

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Scott St. Amand January 6, 2020
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