Case: Charitable Contribution Deduction Properly Denied for Lack of Substantiation (D.C. Cir.) (IRC §170)

Limited liability company (LLC) was not entitled to a charitable contribution deduction where it failed to meet substantiation requirements, the D.C. Circuit Court of Appeals held. LLC acquired a donated a future interest in a piece of commercial property to University. LLC took a $33 million charitable donation deduction, but the IRS disallowed the deduction finding that LLC inflated to the property value to offset the tax liability of the owners. The Tax Court previously upheld the IRS’s determination, including the assessment of a 40% penalty, finding that LLC failed to substantiate the value of the donated property. On appeal, ...