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The Tax Court has held that a series of trusts, which included a charitable remainder annuity trust, formed by a physician and his wife according to the instructions of a...

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16 Apr 2013 | U.S. Tax Court | National Publication | News story

The Tax Court has sustained the IRS's denial of an LLC's income tax charitable deductions for a bargain sale in connection with a settlement agreement based on 1) its failure to satisfy the contemporaneous written acknowledgment requirement of section 170(f)(8) and...

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13 Mar 2013 | U.S. Tax Court | National Publication | News story

The Tax Court has denied the income tax charitable contributions for an individual who founded an animal rescue organization because she failed to provide herself with contemporaneous written acknowledgments from her own organization for her contributions. The fact...

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The Tax Court has imposed deficiencies and accuracy-related penalties against an individual for noncash charitable contribution deductions she claimed on her Schedule A, Itemized Deductions based upon improper substantiation.

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The U.S. Tax Court has denied a couple's income tax charitable deduction for the donation of stock in a corporation to charity because the appraisal obtained by the couple placed a value on the underlying property of the corporation rather than its stock. ...

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29 Jan 2013 | U.S. Tax Court | National Publication | News story

The Tax Court has denied a couple's income tax charitable deduction for a conservation easement on a golf course. According to the court, a provision in the agreement that permitted the donors to change what real property was subject to the easement violated section...

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24 Jan 2013 | U.S. Tax Court | National Publication | News story

In a case on remand from the U.S. Court of Appeals for the Second Circuit, the U.S. Tax Court has held the an individual is not entitled to an income tax charitable deduction for the donation of a façade conservation easement on her home because it didn't reduce the...

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24 Jan 2013 | U.S. Tax Court | National Publication | News story

In addition to denying deductions for capital loss carryovers and applying a zero cost basis to the value of stock, the U.S. Tax Court has denied a taxpayer's income tax charitable deduction carryovers because he failed to prove he ever made the initial charitable...

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The United States District Court for the District of Idaho has refused to dismiss the government's counterclaim for a civil fraud penalty in connection with a couple's $3 million claimed income tax charitable deduction in connection with a donated conservation...

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On remand from the U.S. Court of Appeals for the Fifth Circuit, the Tax Court has revalued a qualified conservation contribution and held the donors liable for additional tax and imposed accuracy-related penalties because reasonable cause for the underpayment...

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The appeals court for the seventh circuit has affirmed the convictions of six defendants who conspired to defraud the United States by impeding and impairing the functions of the Internal Revenue Service ("IRS") and committed offenses against the United States,...

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The U.S. Court of Appeals for the 10th Circuit has affirmed the tax court's value of a conservation easement. The taxpayer, Trout Ranch, LLC, purchased some 450 acres of land in Gunnison County, Colorado, with the aim of developing home sites on a small segment...

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In Huda T. Scheidelman v. Comm’r, the US. Court of Appeals, Second Circuit, vacated the Tax Court’s decision and remanded the case to the Tax Court.  This new case is important for two major reasons—it defines what is acceptable as a...

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In this tax-refund dispute involving an alleged tax shelter scheme called the S corporation Charitable Contribution Strategy, a District Court has refused to allow the plaintiffs move to bifurcate the jury trial into a tax phase and a penalty phase.

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19 Jul 2012 | U.S. Tax Court | National Publication | News story

The Tax Court has ruled that a group of donors satisfied the substantiation requirements of section 170(f)(8) for income tax charitable deduction purposes with respect to the contribution of a conservation easement through their limited liability company.

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Earlier this month the PGDC reported on Joseph Mohamed Sr. et ux. v .Commissioner in which a couple's income tax charitable deductions for tranfers of several valuable parcels of real property to a charitable remainder unitrust were denied...

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The U.S. Court of Appeals for the Federal Circuit has reversed a Court of Claims' dismissal of an IRS determination that certain taxpayers' transfers of their partnership interests to charitable remainder trusts were shams in connection with so-...

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14 Jun 2012 | U.S. Tax Court | National Publication | News story

The Tax Court has held that a couple's deduction for a donation of a façade conservation easement was not allowed because the couple failed to attach a qualified appraisal for purposes of section 170. Further ruled, the reasonable cause exception...

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4 Jun 2012 | U.S. Tax Court | National Publication | News story | 2 comments

The Tax Court has upheld an IRS denial of income tax charitable deductions for a couple's donation of several parcels of real property to a charitable remainder unitrust because the appraisals, which where prepared by the husband, who was a real estate broker...

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23 May 2012 | U.S. Tax Court | National Publication | News story

The Tax Court has denied a couple's income tax charitable deduction and imposed a deficiency and accuracy-related penalty because the written acknowledgment provided by the couple lacked essential information required under section 170(f)(8); specifically, their...

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Recent activity

Tax Court Denies Deductions and Imposes Penalties

Tax Court Denies Deduction for Facade Easement

Battle of the Appraisers: Taxpayer Prevails in Value of Conservation Easement

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Heard on the Web: Important Legal Ruling Impacts Planned Giving Marketing

Foundation Not Supporting Organization Court Rules

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