Reports of the United States Tax Court, Volume 140, January 1, 2013, to June 30, 2013

Reports of the United States Tax Court, Volume 140, January 1, 2013, to June 30, 2013
Title:
Reports of the United States Tax Court, Volume 140, January 1, 2013, to June 30, 2013
Agency Publisher: 
Format:
Hardcover
USA Price: 
$48.00
$24.00
Display Foreign Price
Stock:
In stock
GPO Stock Number:
028-005-00215-9
ISBN:
9780160924095
Description

In Reports of the United States Tax Court, Volume 140, January 1, 2013, to June 30, 2013, Petitioner husband (‘‘P–H’’) contributed cash and a conservation easement to N, a charitable organization. Before the contribution, N at P–H’s request issued to P–H a side letter which promised that, in the event R disallows Ps’ charitable contribution deductions, N ‘‘will promptly refund your entire cash endowment contribution and join with you to immediately remove the facade conservation easement from the property’s title’’. Ps claimed charitable contribution deductions for the cash and easement donations. R contends the side letter made those contributions conditional gifts that are not deductible under I.R.C. sec. 170, since the likelihood that N would be divested of the cash and easement was not negligible. Held: Ps’ charitable contribution deductions are not allowed because at the time of P–H’s contributions, the possibility that the deductions would be disallowed and, as a result, that N would return the contributions was not ‘‘so remote as to be negligible’’, under 26 C.F.R. secs. 1.170A–1(e), 1.170A–7(a)(3), and 1.170A–14(g)(3), Income Tax Regs.

The United States Tax Court is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 providing (in part) that Congress has the power to constitute Tribunals inferior to the Supreme Court. The Tax Court "specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the 'full payment rule')."

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Audience

Lawyers specializing in taxes, taxpayers, political scientists, economists, and students and professors studying tax law may be interested in this information.

Product Details

Availability Details:
In Stock
USA Price:
$24.00
International Price:
$33.60
Publisher:
Tax Court
Author:
  • Murphy, Sheila A.
Key Phrases:
  • Tax Court of the United States Reports, V. 140
  • Reports of the United States Tax Court, V. 140
  • United States Tax Court
  • Taxation
Weight:
2.0625
Quantity Price:
Discount
Cover:
Cloth
Unit of Issue (US):
1
Unit of Issue (Non-US):
1
Record Creation Date:
05/16/2014
Last Status Update:
02/05/2019
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