by admin | Jan 4, 2023 | Tax
Kenneth M. Brooks v Com may be the final decision this year in the IRS battle with dubious conservation easement deductions. The IRS disallowed the deduction on three separate grounds independent of valuation. There was not a proper acknowledgement by the donee,...
by admin | Dec 30, 2022 | Tax
There was a real shocker in the December 6th (2022-218) issue of the EO Tax Journal. In the Editor’s Notebook section Paul Streckfus was commenting on an article by Roger Coinavaux calling for reform of donor advised funds. Streckfus was his usual gloomy self...
by admin | Dec 23, 2022 | Tax
As somebody who believes that the syndicated conservation easements (SCE) constitute an industry based on nonsense, I want to be able to tell you that if you are offered the chance to participate in one, you absolutely should not. I can’t really do that though. ...
by admin | Dec 15, 2022 | Tax
Tenth Circuit upholding the Tax Court’s ruling in the case of Preston Olsen may signal the revival of a once successful IRS technique for attacking tax shelters. Code Section 183 – Activities not engaged in for profit – is commonly rereferred to as...
by admin | Dec 2, 2022 | Tax
The full Tax Court in one of its regular decisions (Green Valley Investors LLC) has dealt a blow against the IRS in its struggle with abusive syndicated conservation easements. A key IRS move in the fight was Notice 2017-10 which made certain syndicated conservation...
by admin | Nov 30, 2022 | Tax
In an upcoming issue of Think Outside The Tax Box , there will be a piece by me about the current state of the Cohan rule. In 1930 Learned Hand writing for the Second Circuit instructed the Board of Tax Appeals (the predecessor to the Tax Court) to take another look...
