Donors of conservation easements have just been put on notice by the Tax Court. Frequently, donors of conservation easements (or related parties) own nearby property. The Tax Court recently denied a deduction for a conservation easement where, without any expert opinion, it determined there was an expectation that contiguous property would increase in value. It…
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In a case with some very interesting legal issues (at least “the kind of conundrum only tax lawyers love”), the IRS is denied penalties for failing to produce the signature of a supervisor. The Tax court gave an early Christmas present to a handful of taxpayers including the Estate of Michael Jackson and Warren Sapp (consolidated…
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The Alaska Supreme Court ruled that Alaska does not have exclusive jurisdiction to hear claims of whether conveyances to an Alaska domestic asset protection trust (“DAPT”) were fraudulent transfers. In Toni 1 Trust v. Wacker, 2018 WL 1125033 (Alaska, Mar. 2, 2018), as judgments were being entered against them, Bertran and Barbara Tangwall transferred Montana…
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Yet again, a taxpayer loses for not properly and contemporaneously documenting his intentions. Here is another lesson on the importance of properly documenting loans (i.e. don’t just “book” as loans but have written loan documents contemporaneous with the advance). Mr. Burke made a number of advances to a business operated by his friend. Although the…
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The Trump era brings about changes to the world of tax law and many planning opportunities. But with it, many unintended consequences may require people to review their current plans. In doing so, people might find that there are opportunities which could significantly lower their tax bills. On December 22, 2017, the Tax Cuts and…
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