Legal Opinion

Chandler v. Comm'r

United States Tax Court

Decided May 14, 2014No. Docket No. 16534-08Published

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

LOGAN M. CHANDLER AND NANETTE AMBROSE-CHANDLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Chandler v. Comm'r

Docket No. 16534-08.

United States Tax Court

142 T.C. 279; 2014 U.S. Tax Ct. LEXIS 17; 142 T.C. No. 16;

May 14, 2014, Filed

Decision will be entered under Rule 155.

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…

2Cases cited8 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  3. Commissioner v. SimmonsCourt of Appeals for the D.C. Circuit · 2011
  4. Hilborn v. CommissionerUnited States Tax Court · 1985
  5. Wolfsen Land & Cattle Co. v. CommissionerUnited States Tax Court · 1979

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