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IRS Hangs Tough On Conservation Easements

IRS Hangs Tough On Conservation Easements

The IRS Chief Counsel has signaled with CCA 202130014 that the Service will be continuing its hard line on conservation easements.  The engine of every abusive syndicated conservation easement is a vastly inflated appraisal.  Rather than focus on the appraisal issue,...
Did IRS Robots Cause The Tax Court Petition Flood?

Did IRS Robots Cause The Tax Court Petition Flood?

Recently I was puzzling about how it could be that the Tax Court had by mid-August received more petitions than it had in total in each of the past three years.  Had I not had the good fortune to retire from active practice in 2018, I might have known. There is a good...
Tax Court Swamped By Flood Of Petitions

Tax Court Swamped By Flood Of Petitions

The United States Tax Court is one of the most accessible courts in the federal system, maybe even overall.  Well here is some good news and bad news about the Tax Court.  The bad news is that it is absolutely swamped by a flood of petitions.  The good news ?  Well...
Michael Jackson Case Could Support Income Tax Savings

Michael Jackson Case Could Support Income Tax Savings

The Tax Court decision in the case of the Estate of Michael Jackson is a rare combination.  The celebrity nature of the case broke it out of the tax ghetto of the blogosphere, which doesn’t happen every day.  And within the tax world it sets a sort of precedent...