Deloitte – IRS Insights – March 2020: Tax Court Denial of Conservation easement; Enforcement Developments

Tax Court Tentatively Disallows Conservation Easement Deduction Due to Omitted Required Basis Information The Tax Court disallowed a conservation easement charitable contribution deduction because the taxpayer’s return omitted the cost or adjusted basis of the donated property from the appraisal summary and rejected the taxpayer’s argument that it strictly or substantially complied with the regulatory … Continue reading Deloitte – IRS Insights – March 2020: Tax Court Denial of Conservation easement; Enforcement Developments

IRS Releases two updated IRA publications and other online resources help taxpayers planning for retirement

The Internal Revenue Service has updated two comprehensive publications designed to help anyone making IRA contributions or receiving IRA distributions for tax year 2019 or considering making retirement donations before April 15, 2020. The 2019 editions of Publication 590-A, Contributions to Individual Retirement Arrangements (IRAs) and Publication 590-B, Distributions from Individual Retirement Arrangements (IRAs), are both now … Continue reading IRS Releases two updated IRA publications and other online resources help taxpayers planning for retirement

Crawford & Blattamachr: Basis and Bargain Sales: Income Tax and Other Concerns, The Tax Lawyer (2020)

Bridget J. Crawford, Pace University School of Law, and Jonathan G. Blattmachr, have made available for download their forthcoming Tax Lawyer article, Basis and Bargain Sales: Income Tax and Other Concerns. The Abstract is as follows: This article explores the income tax consequences of the sale during lifetime and at death of property for less … Continue reading Crawford & Blattamachr: Basis and Bargain Sales: Income Tax and Other Concerns, The Tax Lawyer (2020)

IRS updates guidance on business expense deductions for meals and entertainment

The Internal Revenue Service has issued proposed regulations on the business expense deduction for meals and entertainment following changes made by the Tax Cuts and Jobs Act (TCJA). The 2017 TCJA eliminated the deduction for any expenses related to activities generally considered entertainment, amusement or recreation. It also limited the deduction for expenses related to food and … Continue reading IRS updates guidance on business expense deductions for meals and entertainment

Entin: Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses Holland & Knight Alert (Feb. 20, 2020)

Seth J. Entin, of Holland & Knight, has published an article, Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses Holland & Knight Alert (Feb. 20, 2020). The abstract is as follows: The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border … Continue reading Entin: Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses Holland & Knight Alert (Feb. 20, 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)

Essner v. Commissioner, T.C. Memo 2020-23: Distributions From Inherited IRA Considered Taxable Income

The Tax Court held that taxpayer’s IRA distributions were taxable income for two tax years at issue.  Taxpayer inherited the IRA from his mother and received two separate distributions during the two tax years at issue, which he did not report because he did not believe he owed tax on the distribution.  At trial, taxpayer … Continue reading Essner v. Commissioner, T.C. Memo 2020-23: Distributions From Inherited IRA Considered Taxable Income