Tax Policy Center Conference: Taxes and the Future of Philanthropy (Feb. 18, 2020)

The Urban-Brookings Tax Policy Center and the American Tax Policy Institute held a joint conference on February 18, 2020 on Taxes and the Future of Philanthropy. The summary of the conference is as follows: The philanthropic sector currently faces a difficult challenge: Recent changes to the tax law leave only about 10 percent of households, … Continue reading Tax Policy Center Conference: Taxes and the Future of Philanthropy (Feb. 18, 2020)

TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Drafting Error Costs Client $16 Million Deduction (Feb. 10, 2020)

Bryan Camp has published an article on the Tax Prof Blog, entitled Lesson From The Tax Court: Drafting Error Costs Client $16 Million Deduction (Feb. 10, 2020).  The article begins as follows: Tax statutes and tax regulations mostly use words to talk about numbers.  One of the basic lessons I must teach students is how … Continue reading TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Drafting Error Costs Client $16 Million Deduction (Feb. 10, 2020)

Railroad Holdings, LLC v. Commissioner, T.C. Memo 2020-22 (Feb. 5, 2020): LLC Not Entitled to Charitable Conservation Deduction for Conservation Easement

In Railroad Holdings, LLC v. Commissioner, T.C. Memo 2020-22 (Feb. 5, 2020) the Tax Court held that an LLC was not entitled to a charitable contribution deduction for a conservation easement. The taxpayer executed a deed declaring a conservation easement in favor of a tax-exempt charitable organization. The deed provided that, if the easement was … Continue reading Railroad Holdings, LLC v. Commissioner, T.C. Memo 2020-22 (Feb. 5, 2020): LLC Not Entitled to Charitable Conservation Deduction for Conservation Easement

Carter v. Commissioner, T.C. Memo 2020-21: Married Individuals Denied Charitable Contribution Deductions; Supervisory Approval Not Met

In Carter v. Commissioner, the Tax Court upheld the disallowance of charitable contribution deductions for the conveyance of an easement to a qualified organization. The opinion synopsis is as follows: DH, a partnership of which Ps were partners, conveyed to NALT, a "qualified organization" within the meaning of I.R.C. sec. 170(h)(3), an easement that restricts … Continue reading Carter v. Commissioner, T.C. Memo 2020-21: Married Individuals Denied Charitable Contribution Deductions; Supervisory Approval Not Met

Rev. Proc 2020-8: Form 1023 – application for tax exempt status under Section 501(c)(3) must be filed electronically

The IRS has released guidance in Rev. Proc 2020-8 that requires electronic submissions of Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code. The guidance provides a 90-day transition relief period, during which paper Form 1023 applications will be accepted. This revenue procedure also modifies language related to the … Continue reading Rev. Proc 2020-8: Form 1023 – application for tax exempt status under Section 501(c)(3) must be filed electronically