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 [...]
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 [...]
Despite the relative rarity of an individual taxpayer’s file being brought to United States Tax Court or even audited, many taxpayers nevertheless fear the Internal Revenue Service (IRS) coming after them. This is not without good reason. Responding to an IRS audit alone can be time consuming and involves obtaining and compiling numerous documents. That [...]
On April 20, 2017, the United States Tax Court (Court) held in favor the petitioners, John C. Trimmer and Susan Trimmer (together, the Trimmers) against the Commissioner of Internal Revenue, regarding the Internal Revenue Service’s (IRS’s) authority to consider a hardship waiver and the notion that the IRS’s authority on the hardship waiver is not [...]