Most Recent Posts
Conservation Easement Reform – 250% Is Too Much
This has been a big month in the struggle against abusive syndicated conservation easements. There were three Tax Court decisions disallowing over $30 Million in deductions. And now we have the IRS updated report that comes largely from the filings required by its Notice 2017-10.
If Spouse Is Behind Bars Think Before Filing Jointly
I have been noting these cases for a long time, and Joe takes the cake for the most egregious example of somebody who should not have filed jointly.
Response To Deconstruction Deduction Post
Appraisers are now collaborating with the IRS, appraisal associations, and reuse organizations to solidify best practices within our specialty.
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.
War On Easement Deductions- $30 Million Denied In Three Cases
It has nothing to do with the case, but the history of Aiken County is fascinating. It was formed during Reconstruction and formerly enslaved African Americans had a strong role in its governance. It was the site of the Hamburg Massacre in 1876, which was a big step in the ultimate disenfranchisement of African Americans. Quite a few people I know are pretty jittery about the upcoming 2020 election. It will be no comfort to them, but I think that whatever happens in the 2020 election won’t be nearly as bad as 1876.
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 Holdings.
Wrapping The Green Flag Around Tax Shenanigans
The intellectual justification for why syndications can work is that there is this other value to be placed on land for purposes of charitable deduction – the discounted cash flow from a hypothetical highest and best use. In that view, it does not matter what anybody is currently willing to pay for the land any more than it matters what the used building materials will go on the shelf for in the aggressive deconstruction deductions.
I doubt that the deconstruction deductions will end up creating as much drama as the conservation easements, but we will see.
Valuation Abuse In Conservation Easements – Rare Or Pervasive?
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.
Tax Court Demolishes Deconstruction Deduction
Image by By Arturo Espinosa SeguirJacques Derrida for PIFALPencil on Fabriano. - This piece really has nothing to do with the kind of deconstruction that Derrida...
Don’t Drop Your Tax Court Petition In the Mailbox
The envelope that arrived at the Tax Court was kind of extraordinary. It had been in the USPS system for several weeks, without having any marks at all placed on it. This created a real puzzler for Judge Vasquez.