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Court Denies Conservation Easement Deduction for Defective Contemporary Written Acknowledgement

By Steven Miller, former IRS Acting Commissioner and alliantgroup National Director of Tax On March 23, 2016, the Tax Court issued a decision upholding the IRS’s disallowance of a charitable deduction for a contribution of a conservation easement based on the taxpayer’s failure to satisfy the strict substantiation requirements of section 170(f)(8). In French v.…

District Court Finds Private Equity Funds Liable for Portfolio Company’s Withdrawal Liability

In a recent decision, a Massachusetts Federal District Court judge held two private equity funds, Sun Capital Partners III and Sun Capital Partners IV (the Funds), jointly and severally liable for a $4.5 million multiemployer pension plan withdrawal liability incurred by a commonly owned portfolio company, Scott Brass, Inc. (SBI). The court supported its decision…

COURT ACTION

Watch the Formalities: Government Wins as Court Ignores Taxpayer Structure in Wrongful Levy Case In WRK RARITIES, LLC v. U.S., ET AL., CaseNo. 4:13cv791, DC OH, 02/29/2016, the taxpayer filed a wrongful levy suit against the government. WRK Rarities, LLC (WRK) is an entity 100 percent owned by William Kimpel (Kimpel) and prior to establishing…

alliantnational’s Steve Miller and John Dies Discuss Appeals Process and Pre-Audit Tactics in Captive Insurance Examinations

In a March 10 American Bar Association Webinar, Steve Miller and John Dies discussed useful tactics and strategies for dealing with an IRS examination of a captive insurance company. The hour long webinar focused on tax issues for small captive owners both before and after IRS tax controversy arises. Miller discussed pre-audit strategies captive insurance…

COURT ACTION

Golf Courses and Conservation Easements By Steven Miller, alliantgroup National Director of Tax and former IRS Acting Commissioner The government has won the most recent skirmish in the ongoing battle between the IRS and taxpayers relating to the parameters of what can be claimed as a charitable deduction for a contribution of a conservation easement.…

COURT ACTION

In December 2011, the IRS issued Technical Advice Memorandum 201149021, concluding that a residual value insurance contract that ‘insures against market decline is not a contract of insurance for federal income tax purposes.” On September 21, 2015, in R.V.I. Guaranty Co., LTD. & Subsidiaries, v. Commissioner of Internal Revenue, the Unites States Tax Court disagreed,…

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Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave. Washington, D.C. 20004
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© 2021 alliantNational.- All Rights Reserved.

aNlogo-footer3@2x

Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave.
Washington, D.C. 20004
202.888.7006

© 2021 alliantNational. - All Rights Reserved.

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