U.S. Tax Court Upholds Disallowance of Charitable Contribution Deduction for Acknowledgment Defects

The U.S. Tax Court, in a memorandum opinion, held that the taxpayers’ charitable contribution deduction for donated property was properly disallowed because they failed to obtain a contemporaneous written acknowledgment that satisfied statutory requirements, granting the IRS’s motion for summary judgment. Taxpayers, a married couple, donated a 50 percent interest in real property to a city in 2018 and claimed a charitable contribution deduction of $332,500 on their joint return. Taxpayer’s cousin originally purchased the property and later transferred it to both the cousin and Taxpayer before being donated to the city for conservation purposes. The IRS issued a notice ...