Chandler v. Comm'r
United States Tax Court
Ps granted to a qualified organization facade easements on two historic homes they owned. They claimed charitable contribution deductions for 2004, 2005, and 2006 based on fair market value appraisals of the easements. A portion of each of the 2005 and 2006 deductions resulted from a carryforward of a deduction they first claimed for 2004. R disallowed the deductions because he determined the easements were valueless.
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Ps granted to a qualified organization facade easements on two historic homes they owned. They claimed charitable contribution deductions for 2004, 2005, and 2006 based on fair market value appraisals of the easements. A portion of each of the 2005 and 2006 deductions resulted from a carryforward of a deduction they first claimed for 2004. R disallowed the deductions because he determined the easements were valueless. R imposed gross valuation misstatement penalties on the underpayments resulting from the alleged easement overvaluations. Ps sold one of the homes in 2005 and reported capital…
1Opinion of the Court
Goeke, Judge:
Petitioners owned two single-family residences in Boston’s South End Historic District. They granted a facade easement on each property to the National Architectural Trust (NAT) and claimed related charitable contribution deductions for taxable years 2004, 2005, and 2006. In 2005 petitioners sold one of the properties and reported a capital gain. Petitioners claimed a basis in the property that reflected $245,150 of improvements.
Respondent disallowed petitioners’ charitable contribution deductions because he determined the easements had no value. He also found that petitioners…
2Cases cited7 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Commissioner v. SimmonsCourt of Appeals for the D.C. Circuit · 2011
- Hilborn v. CommissionerUnited States Tax Court · 1985
- Wolfsen Land & Cattle Co. v. CommissionerUnited States Tax Court · 1979
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Kaufman v. Commisioner of Internal RevenuCourt of Appeals for the First Circuit · 2015
- Zarlengo v. Comm'rUnited States Tax Court · 2014
- Reisner v. Comm'rUnited States Tax Court · 2014
- Anthony M. Kissling & Suzanne R. Kissling v. CommissionerUnited States Tax Court · 2020
- Chandler v. Comm'rUnited States Tax Court · 2014
2 more not listed; retrieve them via the Exa API.