Chief Counsel Gives Narrow Scope To Partnership Liability Regulations
At any rate, it was nice to have those regulations, because sometimes it is important how the liabilities are allocated among the partners and what flavor the liabilities are. One situation where it is important whether liabilities are recourse or nonrecourse is when property is foreclosed. If the liability is recourse, the balance is considered proceeds of sale to the extent of the fair market value of the property and the balance is income from the discharge of indebtedness. If the liability is nonrecourse, it is all proceeds of the sale. Which one is better?
In Defense Of Conservation Easement Charitable Deductions
The truth is that these 70 plus cases represent a very small minority of land conservation activities across the nation. There are more than 1,700 land trust working at the local level to preserve wildlife habitat area, ecosystems that produce clean water and air, scenic rural landscapes and recreation areas, historic sites such as civil war battlefields, and productive agricultural and forestry resources that supply our nation with food and timber.
Working within their own community these groups have harnessed local enthusiasm and voluntary action to permanently preserve and protect as much as one million acres per year. Since the 1970’s, there have been tens of thousands of conservation easements donated on tens of millions of acres to conservation groups across the nation. The cases brought by the IRS and state tax departments represent far less than 1 percent of the donations that happen in even one year.
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Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.