According to the income tax regulations, no income tax charitable deduction is permitted for a conservation easement in property which is subject to a mortgage unless the mortgagee subordinates its rights in the property to the right of the qualified organization to...
In a memorandum opinion, the Tax Court has held that deeds transferred by individuals are consistent with the requirements of IRC 170(h)(4)(A)(ii) and are therefore qualified conservation contributions. Although the court made a valuation adjustment, it did not...
The Tax Court has held that co-owners of land who donated conservation easements overvalued the easements based on the fact the highest and best use as argued by the IRS and agreed to by the court was not as a gravel mine but, rather, as agricultural property....
The Tax Court has denied charitable deductions for conservation contributions made by a couple and two individuals because donations may be extinguished by mutual consent of the parties and, therefore, fail as a matter of law to comply with the...
The Tax Court has ruled that a settlement agreement cannot be used as a contemporaneous written acknowledgment within the meaning of section 170(f)(8)(A) to substantiate an income tax charitable deduction for the donation of a conservation easement.
The Tax Court has held that a donor is not entitled to an income tax charitable deduction because she failed to establish that she conveyed legal title of donated house to the charitable donee. Consequently the value of the house and costs incurred and related to...
The Tax Court has affirmed the IRS's denial of a couple's claimed income tax charitable contribution deduction for a facade easement and some cash, and imposed accuracy-related penalties for the cash donations.
The Tax Court has denied an income tax charitable deduction for the contribution of a facade easement based on the donors' failure to file a properly completed Form 8283 and attach to their tax return a qualified written
appraisal. In addition, the contemporaneous...
The Tax Court has sustained the IRS's deficiency determination and imposed accuracy-related penalties against an individual who failed to substantiate her charitable and other itemized deductions.
The Tax Court has reduced the value of a conservation easement granted by a partnership on land it owned and imposed a 30 percentage limitation on the resulting income tax charitable deduction.
The Tax Court has disallowed deductions claimed by an attorney who failed to substantiate numerous itemized deductions, including those for charitable contributions, and has imposed accuracy-related penalties.
The Tax Court has denied a charitable deduction for the contribution of a conservation easement based on its determination the appraisal obtained by the taxpayer lacked significant information that would make it a qualified appraisal as described in Reg. section 1.170A...
The Tax Court has denied an individual's income tax charitable deductions for cash offering plate donations made to a church based on his failure to substantiate his deductions. Other business-related deductions were denied as well.
The Tax Court has ruled that a couple is not entitled to an income tax charitable deduction for gifts made to a radio station based on the fact it was not a qualified charitable organization. In order to claim a deduction for a charitable contribution, a taxpayer...
In a memorandum opinion, the Tax Court has ruled that even though the IRS prevailed in a matter of estate tax deficiency, the estate will not be held liable for accuracy-related penalties because its executor relied in good faith upon an adviser he hired to provide...
The Tax Court has ruled that although a partnership successfully challenged the IRS in claiming a charitable contribution deduction for the bargain sale of real property in connection with an eminent domain proceeding, it is not entitled to recover administrative...
The Tax Court has denied a couple's income tax charitable deduction and imposed penalties in connection with a contribution of a facade conservation easement based on their failure to obtain a qualified appraisal as required under IRC section 170 and section 1.170A...
No Proof, No Deduction
The Tax Court has denied a couple's claimed income tax charitable deductions and imposed accuracy-related penalties based on their failure to provide any substantiation for their alleged gifts.
The Tax Court has denied charitable contribution deductions for donations for gifts made by a couple to needy individuals because
they were private gifts rather than made through a qualified organization. The court did allow some deductions for gifts
to...
The Tax Court has denied a couple's claimed income tax charitable deduction for a facade easement based on the fact they failed to raise any genuine issue of material fact regarding their compliance with the regulations.
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
Deductions Denied for Failure to Substantiate; Accuracy-Related Penalties Imposed
Charitable Contribution Deductions Denied for Failure to Provide Proof
Couple Penalized for Negligently Claiming Mostly Undocumented Deductions
Tuition Payments Are Not Charitable Contributions