15 W. 17th St. LLC v. Comm'r
United States Tax Court
On its 2007 partnership return LLC claimed a charitable contribution deduction of $64,490,000. In order to substantiate a charitable contribution deduction of $250 or more, a taxpayer must secure and maintain in its files a "contemporaneous written acknowledgment" (CWA) from the donee organization. I.R.C. sec. 170(f)(8)(A). The CWA must state (among other things) whether the donee provided the donor with any goods or services in exchange for the gift.
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On its 2007 partnership return LLC claimed a charitable contribution deduction of $64,490,000. In order to substantiate a charitable contribution deduction of $250 or more, a taxpayer must secure and maintain in its files a "contemporaneous written acknowledgment" (CWA) from the donee organization. I.R.C. sec. 170(f)(8)(A). The CWA must state (among other things) whether the donee provided the donor with any goods or services in exchange for the gift. I.R.C. sec. 170(f)(8)(B)(ii). The substantiation requirements of subparagraph (A) do not apply to a contribution "if the donee organization…
1Opinion of the Court
15 WEST 17TH STREET LLC, ISAAC MISHAN, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
15 W. 17th St. LLC v. Comm'r
Docket No. 25152-11
United States Tax Court
2016 U.S. Tax Ct. LEXIS 37; 147 T.C. No. 19;
December 22, 2016, Filed
An order will be issued denying petitioner's motion for partial summary judgment.
On its 2007 partnership return LLC claimed a charitable contribution deduction of $64,490,000. In order to substantiate a charitable contribution deduction of $250 or more, a taxpayer must secure and maintain in its files a "contemporaneous written…
Also in this document: Concurrence; Dissent · Foley; Dissent · Gustafson.
2Cases cited45 opinions
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