IRS Disallowed Charitable Deductions Lacking Donative Intent; Tax Court Disagrees
In his Estate Planning and Philanthropy column, Conrad Teitell discusses 'McGrady', T.C. Memo, 2016-233, a case in which a donor claimed $4.7 million in charitable deductions for conservation easement gifts. The IRS found that the donor lacked donative intent, and the Tax Court held otherwise.
June 23, 2017 at 02:03 PM
8 minute read
What happened: Donor claimed $4.7 million in charitable deductions for conservation easement gifts.
The IRS disallowed the deductions: Donors lacked donative intent; failed to satisfy various reporting requirements; overvalued the donated property; and received return benefits in exchange for their gifts.
The IRS determined tax deficiencies totaling $1,500,377 for the years 2007 through 2011.
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