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IRS Conducts Examination Without Coordination Or Clarity

IRS Conducts Examination Without Coordination Or Clarity

A Tax Court decision last week gives a clear demonstration of the sad state of IRS compliance efforts and a clever though fruitless argument by the taxpayer. The taxpayer was a physician, so I will refer to him as “the doctor”. You can get his actual name from the...

War On Easement Deductions- $30 Million Denied In Three Cases

Originally published on Forbes.com. Last week was a big week for disallowing conservation easement deductions in the Tax Court with two big-dollar decisions coming out. We already covered Nathaniel and Stella Carter, which leaves Railroad Holdings LLC for today and...

Tax Court Denies Millions In Easement Deductions

The Tax Court gave a one-two punch to conservation easement deductions with its decisions in the case of Nathaniel and Stella Carter on February 3rd and Railroad Holdings LLC on February 5th. Judge Halpern had the Carters and Judge Gustafson was working on Railroad...

Wrapping The Green Flag Around Tax Shenanigans

Earlier this month I wrote about Second Chance, a not for profit in Baltimore that combines environmental concerns with job creation. In order to cover the story of a Tax Court decision concerning a donation to Second Chance, I had to learn a bit about deconstruction....

Valuation Abuse In Conservation Easements – Rare Or Pervasive?

Originally published on Forbes.com. Way back in 2011 covering a private letter ruling that disallowed exempt status for a sketchy land trust I came up with a prescient title Conservation Easements A New Field For Villainy. My continuing coverage earned me a phone call...