Case: U.S. Court of Appeals Upholds Tax Court’s Decision Disallowing Charitable Deduction

The U.S. Court of Appeals for the 6th Circuit affirmed the Tax Court’s decision to disallow the taxpayer’s charitable deduction for an easement donation and impose penalties. Taxpayer, a partnership, purchased a historic building for $6 million and claimed a $22 million charitable deduction for donating an easement on the building 16 months later. The IRS disallowed the deduction and imposed penalties, finding that the taxpayer claimed it for the wrong tax year, substantially overvalued it, and failed to document expenses. The court held that the taxpayer improperly claimed the deduction in its 2016 return when it should have been ...