Reisner v. Comm'r
United States Tax Court
In 2004 Ps granted to a qualified organization a facade easement on a townhouse they owned. With respect to that donation they claimed a charitable contribution deduction for 2004 and carryover charitable contribution deductions for 2005 and 2006. R disallowed the deductions because he determined the easement was valueless.
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In 2004 Ps granted to a qualified organization a facade easement on a townhouse they owned. With respect to that donation they claimed a charitable contribution deduction for 2004 and carryover charitable contribution deductions for 2005 and 2006. R disallowed the deductions because he determined the easement was valueless. R also determined that Ps were liable for a gross valuation misstatement penalty pursuant to I.R.C. sec. 6662(h) on the underpayment attributable to the easement overvaluation for each year. Ps and R now agree that the easement Ps contributed to the qualified organization…
1Opinion of the Court
EDWARD M. REISNER AND MANDA K. WEINTRAUB, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Reisner v. Comm'r
Docket No. 18426-09.
United States Tax Court
T.C. Memo 2014-230; 2014 Tax Ct. Memo LEXIS 227; 108 T.C.M. (CCH) 518;
November 6, 2014, Filed
Decision will be entered.
In 2004 Ps granted to a qualified organization a facade easement on a townhouse they owned. With respect to that donation they claimed a charitable contribution deduction for 2004 and carryover charitable contribution deductions for 2005 and 2006. R disallowed the deductions because he determined the easement was…
2Cases cited7 opinions
- Lorillard v. PonsSupreme Court of the United States · 1978
- Commodity Futures Trading Commission v. SchorSupreme Court of the United States · 1986
- Scheidelman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2012
- 1982 East, LLC v. Comm'rUnited States Tax Court · 2011
- Scheidelman v. Comm'rUnited States Tax Court · 2013
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