The First Circuit has reversed a district court's acquittal of defendants in a joint criminal prosecution for conspiring to defraud the United States by obstructing the functions of the Internal Revenue Service, for corruptly endeavoring to obstruct the due...
The U.S. Court of Appeals for the District of Columbia has held the Tax Court did not err in ruling a donor met the applicable statutory and regulatory requirements in claiming deductions for the donation of conservation easements on the façades of...
The Federal Circuit Court of Appeals has affirmed a Court of Federal Claims opinion and joined with the Second and Third circuits in their holding that securities purchased on margin
by an otherwise tax-exempt organization are debt-financed property, the
income from...
The Ninth Circuit Court of Appeals has affirmed the Tax Court's ruling that taxpayers were not entitled to deduct noncash charitable deductions because the taxpayers failed to comply, either fully or substantially, with the reporting requirements in I.R.C.
Writing for onPhilanthropy.com, attorney Jonathan Gudema reports the U.S. Court of Appeals for the 9th Circuit has issued an opinion in a case involving Robert Dillie this past June. Mr. Dillie operated a fraudulent foundation between 1996 and 2001. This foundation was...
Plaintiffs (appellees) seek a determination that they were entitled to deduct from their Federal income tax return for the taxable year 1964 the replacement value of a life insurance policy which was given by them to a charitable institution, which amount was...
Blogging for TaxProf Blog, editor Paul L. Caron discusses the 10th circuit's denial of a $300,000 charitable deduction claimed by Leslie Stephen Jones, lead counsel for the defense of Timothy McVeigh in the 1995 bombing of the Alfred P. Murrah Federal Building in...
The Ninth Circuit Court of Appeals has affirmed the Tax Court's decision affirming the disallowance of deductions petitioners-appellants claimed for tuition and fees paid to their children's religious day schools.
The Sixth Circuit Court of Appeals has affirmed the Tax Court's holding that a married couple who created business and charitable trusts that lacked economic substance did so fraudulently and were therefore liable for income taxes, self-employment taxes, and civil and...
The Seventh Circuit Court of Appeals has affirmed the Tax Court's denial of an estate tax charitable deduction based on the fact the estate failed to properly reform a defective charitable remainder unitrust via a timely judicial modification and despite the estate's...
The Third Circuit Court of Appeals has affirmed the decison of the District Court in Edmond C. Galloway v. United States in denying an estate tax charitable deduction because a split-interest charitable trust did not take the form of a qualified charitable remainder...
The Sixth Circuit of Appeals has affirmed the Tax Court's decision that a couple's contributions of conservation easements to a nonprofit were qualified conservation contributions and, contrary to the Commissioner's opinion, made "exclusively for conservation purposes."
The Second Circuit of Appeals has affirmed a district court decision that denied a testamentary trust's charitable tax deduction and refund request based on the fact a power of appointment exercised by the surviving spouse was made on her own accord rather than under...
The Sixth Circuit has upheld a Tax Court decision that the Lapham Foundation was a private foundation rather than a supporting organization because it failed the integral-part test of reg. section 1.509(a)-4(i)(3). This case is instructive for gift planners because of...
Citing Addis v. Commissioner, the Ninth Circuit, affirming the Tax Court, has held that a charity failed to provide a good-faith estimate of the value of goods and services that Gary Weiner received in consideration for donations involving split dollar insurance...
Ninth Circuit Judge John T. Noonan, affirming the Tax Court, has held that the National Heritage Foundation failed to provide the value of goods that Charles and Cindi Addis received for contributions to NHF in a charitable split-dollar insurance transaction and has...
The Eighth Circuit has affirmed a CPA's convictions for wire fraud, mail fraud, money laundering, filing false tax returns, making a false declaration before a grand jury, and obstruction of justice for his fraudulent involvement with a couple's charitable trust.
The Eleventh Circuit, affirming the Tax Court decision in Estate of Melvine B. Atkinson, et al. v. Commissioner, has held that the estate wasn't entitled to a charitable deduction for property passing to a purported charitable remainder annuity trust (CRAT) because the...
In an unpublished summary opinion, the Tax Court has ruled a couple cannot claim income tax charitable deductions for unsubstantiated cash contributions, nor can they claim deductions for business expenses because they were not engaged in a trade or business.
A panel for the Sixth District Court of Appeals has reviewed the decision of the United States Tax Court in Jennings v. Commissioner, and determined that oral argument is not needed in its ruling to uphold the lower court's decision. In the original case, Jennings...
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Heard on the Web: Important Legal Ruling Impacts Planned Giving Marketing
Second Circuit Affirms Denial of Testamentary Trust's Charitable Deduction
Foundation Doesn't Qualify as Supporting Organization
Affirmed: Couple Denied Charitable Deduction for Split-Dollar Insurance Transaction