News & Analysis as of

Internal Revenue Service Appraisal Internal Revenue Code (IRC)

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Polsinelli

Tax Court Strikes out Smoltz and Klesko’s Big K SCE, but Provides Relief for Those Facing Fraud Allegations

Polsinelli on

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

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

Polsinelli on

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

Fox Rothschild LLP

IRS Cracks Down on Charitable Contributions of Cryptocurrency

Fox Rothschild LLP on

On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency. In the CCM, the IRS concluded that taxpayers must obtain a ‘qualified appraisal’ if...more

Freeman Law

IRS CCMs on Crypto Donations and Crypto Losses

Freeman Law on

IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition - Introduction - The IRS recently released two chief counsel...more

Burr & Forman

Senate Finance Committee Probing Conservation Easement Abuse

Burr & Forman on

On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of...more

Womble Bond Dickinson

How to Make Charitable Contribution Deductions Vanish in to Thin Air – a Review of the Charitable Contribution Substantiation...

Womble Bond Dickinson on

On July 27, 2018, the Treasury issued final regulations regarding substantiation requirements for cash and noncash charitable contributions. T.D. 9836 (2018). The final Regulations reflect amendments to Section 170 of the...more

Proskauer Rose LLP

Wealth Management Update - March 2016

Proskauer Rose LLP on

March Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The March § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

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