Fraud Risks at Nonprofit Organizations - Part 1
REFRESH Nonprofit Basics: Navigating the Complex Rules That Describe a Public Charity
REFRESH Nonprofit Basics: Overview of Nonprofit Charitable Organization Types: Corporation, LLC, Trust, Association and Fiscal Sponsorship
Nonprofit Quick Tip: State Filings in New Mexico and Utah
Back to Compliance: Reinstating Tax-Exempt Status for a Charity
REFRESH: Loot and Private Foundation Rules – Part 2
REFRESH: Loot and Private Foundation Rules – Part 1
IRS Dirty Dozen Warnings on Charitable Scams
California Regulation of Charitable Fundraising Platforms Part 2 - Reporting Due Diligence, Recordkeeping, and Disclosure Rules
California Regulation of Charitable Fundraising Platforms: Part I - Definitions
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Nonprofit Basics: Unpacking Prudent Investments, PRIs and MRIs
Nonprofit Basics: Scholarship Grant Program IRS Approval Requirements
Nonprofit Quick Tip: State Filings in Rhode Island and New Hampshire
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax
Exceptions to the DAF Definition Under the Proposed Regulations
New Proposed Regulations Defining Donor Advised Fund Terms
In the Weeds With New Supporting Organization Regulations
The Tax Court recently ruled that a new partnership (“New Shoals”) that is deemed to form on a technical termination may use a taxable year that starts on the date of the termination of the old partnership (“Old Shoals”),...more
In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more
In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
Faulty Framework? The question posed above is not intended to be rhetorical. Rather, it is one that the owners of a closely held business should consider thoroughly before transferring or committing any business assets to...more
Summary: In this 49-page opinion the Tax Court addresses a deficiency arising from the charitable contribution of appreciated shares of stock in a closely held corporation to a charitable organization that administers...more
Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more
Summary: This case involves taxpayers, Calvin Lim and Helen Chu (together, “Petitioners”) federal income tax liabilities for 2016 and 2017 with respect to a disallowed charitable contribution deduction....more
Tax Litigation: The Week of December 19th, 2022, through December 23rd, 2022 Starer v. Comm’r, T.C. Memo. 2022-124 | December 20, 2022 |Wells, J. |Docket No. 615-13 Mamadou v. Comm’r, T.C. Memo. 2022-121 | December 20, 2022...more
As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more
Tax Litigation: The Week of May 23rd, 2022, through May 27th, 2022 Genecure, LLC v. Comm’r, T.C. Memo 2022-52 | May 23, 2022 | Jones, J. | Dkt. No. 14916-15. Albrecht v. Comm’r, T.C. Memo 2022-53 | May 25, 2022 | Greaves, J....more
Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Salter v. Comm’r, T.C. Memo. 2022-9 |April 5, 2022 |Lauber, J. |...more
Section 6751(b)(1) of the Internal Revenue Code provides that “[n]o penalty under this title shall be assessed unless the initial determination of such assessment is personally approved (in writing) by the immediate...more
Wither the Weed? It has been one month since Mr. Biden’s inauguration as President of the United States. Among the many questions being asked of President Biden is whether he will seek the decriminalization of cannabis....more
In recent months, the IRS has continued its attack on syndicated conservation easement transactions. Many syndicated partnerships are now under IRS audit or have cases pending before the US Tax Court. Moreover, the IRS has...more
The Tax Court recently issued a full T.C. opinion which will impact a tremendous number of conservation easement donations. In Pine Mountain Preserve, LLLP v. Commissioner, 151 T.C. 4 (2018) the Tax Court found a reservation...more
In Wendell Falls Development, LLC v. Commissioner, T.C. Memo. 2018-45, the Tax Court denied a charitable contribution deduction for a taxpayer’s contribution of a conservation easement because the taxpayer expected to receive...more
The Tax Court’s recent opinion in Roth v. Commissioner, T.C. Memo. 2017-248, raises interesting issues about the need for supervisor approval when the IRS asserts penalties. In 2007, the petitioners in Roth donated a...more
While we’re not even three full months into 2016, the United States Tax Court already has decided two cases, which disallowed tax deductions for donors based on a tax exempt entity’s failure to properly substantiate those...more