federal tax court cases

The Internal Revenue Service (IRS) announced on August 31, 2020 that Coal Property Holdings, LLC and its partners agreed to a disallowance of their $155 million charitable deduction claimed for a conservation easement donation on 3,700 acres in Tennessee (IR-2020-196).

Continue Reading IRS Finalizes Settlement of Syndicated Conservation Easement Transactions Under Initiative to Resolve Pending Cases

On July 9, 2020, the U.S. Tax Court granted partial summary judgment in favor of the Internal Revenue Service (IRS) in four separate cases brought against taxpayers for charitable contributions of conservation easements.  The basis for the judgments against the taxpayers were (i) violation of the proceeds clause under Treas. Reg. § 1.170A-14(g)(6)(ii) which results in a violation of the perpetuity requirement under I.R.C. § 170(h)(5)(a); and (ii) failure to provide the cost basis in IRS Form 8283 which was not substantial compliance with IRS requirements.
Continue Reading Charitable Deductions Denied on Four Conservation Easement Donations