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.
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