U.S. Tax Court

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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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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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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...

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25 Mar 2012 | U.S. Tax Court | National Publication | News story

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...

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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....

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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...

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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.

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25 Apr 2011 | U.S. Tax Court | National Publication | News story

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...

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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.
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30 Mar 2011 | U.S. Tax Court | National Publication | News story
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...
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17 Mar 2011 | U.S. Tax Court | National Publication | News story
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.
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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.
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14 Dec 2010 | U.S. Tax Court | National Publication | News story
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.
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10 Sep 2010 | U.S. Tax Court | National Publication | News story
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...
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31 Aug 2010 | U.S. Tax Court | National Publication | News story

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.

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31 Aug 2010 | U.S. Tax Court | National Publication | News story

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...

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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...
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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

Dieringer v. Commissioner: Estate Tax Charitable Deduction for Bequest of Stock to Private Foundation Limited to Post-Death Redemption Proceeds - A Flawed Result?

Appraisals Performed by Donor Not Qualified Appraisals: Deduction Denied

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