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Wagner Tax Law Blog
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Internal Revenue Service Plans Dozens of Corporate Jet Audits
On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to begin dozens of audits on business aircraft involving personal use, contributing to the Inflation Reduction Act’s efforts to improve tax compliance for high-income individuals and businesses. These audits will focus on aircraft usage by large corporations, partnerships, and wealthy taxpayers, and […]
Two Easements Conserved But Not in Perpetuity
In February of 2020, the United States Tax Court issued a Memo, Railroad Holdings, LLC T.C. Memo. 2020-22 (U.S.T.C. Feb. 5, 2020), and an Order, Rock Creek Holdings, LLC, Tax Court Order, 2/10/2020. Both the Memo and the Order pertain to the conservation easement in dispute in the cases. In the first case, the Court […]
The Challenges for Art Donation (Part 3 of 3): Trouble with $0 Donations
When it comes to the charitable donation of art, the Internal Revenue Service (IRS) has increasingly adopted a predictable strategy, as outlined in part two of this series. Similar to cases involving conservation easements, the IRS can even take the position that donated art is worth $0. While this is the IRS’s most extreme position […]