U.S. Tax Court

 
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In a recent case decided by the Tax Court, Graev, 140 TC No. 17, because of the attendant risk of an IRS disallowance of charitable deductions taken in connection with an contribution of an easement, the donor, a New York attorney, entered into a side agreement that...

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22 Nov 2013 | U.S. Tax Court | National Publication | News story

The Tax Court has ruled that a partnership is not entitled to a charitable contribution deduction for a contribution of a qualified conservation easement because it fails to preserve the entire exterior of the building as required under IRC section 170(h)(4)(B...

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14 Nov 2013 | U.S. Tax Court | National Publication | News story

The Tax Court has ruled that a couple overvalued an open space and facade easement and, therefore, is liable for deficiencies and a 40% gross valuation penalty under Section 6662(h). Although the Court found the the easement was contributed exclusively for...

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27 Sep 2013 | U.S. Tax Court | National Publication | News story

The Tax Court has concluded that based on a change in tax law, the appraisal for a facade easement and development rights in real property is a qualified appraisal pursuant to section 1.170A-13(c)(3)(ii). Consequently, it will now decide at trial if the donors are...

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14 Aug 2013 | U.S. Tax Court | National Publication | News story

In what could be called nothing short of ironic, the U.S. Tax Court has denied charitable deductions and imposed accuracy related penalties on Margaret Payne, an IRS revenue agent who, using the nickname of "Schouchi" and also working as a church secretary...

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28 Jun 2013 | U.S. Tax Court | National Publication | News story

The Tax Court has upheld the IRS's disallowance of a couple's income tax charitable deductions and imposed accuracy-related penalties for contributions of a facade conservation easement and an accompanying cash endowment gift that were conditioned upon the IRS...

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20 Jun 2013 | U.S. Tax Court | National Publication | News story

The U.S. Tax Court has denied a couple's motion to reconsider its decision in which it denied charitable contribution deductions for the couple donation of a conservation easement because they failed to donate a qualified real property interest. In the original case...

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20 Jun 2013 | U.S. Tax Court | National Publication | News story

The U.S. Tax Court has substantiated the IRS's disallowance of a couple's failure to substantiate deductions they claimed for ...

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The Tax Court has upheld an IRS denial of charitable contribution carryover deductions and imposed accuracy-related penalties based a taxpayer's substantial overstatement of the value of a conservation easement on ranch property. 

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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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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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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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Define: U.S. Tax Court

The United States Tax Court is a court of record established by Congress under Article I of the U.S. Constitution. When the Commissioner of Internal Revenue has determined a tax deficiency, the taxpayer may dispute the deficiency in the Tax Court before paying any disputed amount. The Tax Court’s jurisdiction also includes the authority to redetermine transferee liability, make certain types of declaratory judgments, adjust partnership items, order abatement of interest, award administrative and litigation costs, redetermine worker classification, determine relief from joint and several liability on a joint return, review certain collection actions, and review awards to whistleblowers who provide information to the Commissioner of Internal Revenue on or after December 20, 2006.

 

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