The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
The Koontz Decision: Limits Conditions a Government can Impose on Developers
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
On September 21, 2022, the New York State Attorney General Tish James filed a civil lawsuit against former President Donald Trump and the Trump organization alleging fraud and misrepresentation. The Complaint described a...more
Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Domdom v. Comm’r, T.C. Summary Opinion 2022-17 | August 30, 2022 | Carluzzo, J. | Dkt. No. 18270-17S Pressman v. Comm’r, T.C. Summ. Op. 2022-15 |...more
Tax Litigation: The Week of March 14, 2022, through March 18, 2022 Hamilton v. Comm’r, T.C. Memo. 2022-21 | March 15, 2022 |Urda, J. | Dkt. No. 139-19L AptarGroup, Inc. v. Comm’r, 158 T.C. No. 4 | March 16, 2022 |Goeke, J. |...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of October 31 – November 6, 2020 - Glade Creek Partners,...more
The Internal Revenue Service (“IRS”) in an August 31st news release announced what it described as: . . . the completion of the first settlement under its initiative to resolve certain docketed cases involving syndicated...more
Taxpayers who have claimed charitable contribution deductions based on conservation easement arrangements should immediately contact a tax professional. Professionals who have engaged in the marketing of these arrangements...more
On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of...more
Green vs. U.S., No. 16-6371 (10th Cir., Jan. 12, 2018) - Practitioners and donors often forget a pesky donation limitation that applies only to irrevocable trusts: the deduction for a real property donation is limited to the...more
August brought three wins for taxpayers who donated conservation easements that were challenged by the IRS. In all of the cases, terms of the conservation easement deed document carried the day....more
In Notice 2017-10, the IRS has determined that certain conservation easements are now “listed transactions” for purposes of federal tax reporting. “Syndicated” conservation easements are conservation easements donated by a...more
March Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The March § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more
The Administration’s proposed budget for Fiscal Year 2017 features several proposals that would impact charitable organizations and their donors, including proposals to streamline the private foundation excise tax on net...more