Abstract

http://ssrn.com/abstract=2171733
 


 



Trying Times: Important Lessons to Be Learned from Recent Federal Tax Cases


Nancy A. McLaughlin


University of Utah S.J. Quinney College of Law

Stephen J. Small


Law Office of Stephen J. Small, Esq., P.C.

October 2, 2012


Abstract:     
This outline was prepared for a panel discussion on recent case law developments in the conservation easement donation context that took place at the Land Trust Alliance national conference in Salt Lake City, Utah, in early October 2012. The four panelists were Nancy A. McLaughlin, Robert W. Swenson Professor of Law at the University of Utah SJ Quinney College of Law; Stephen J. Small, national expert on conservation easement donation transactions and one of the principal drafters of the Treasury Regulations interpreting Internal Revenue Code § 170(h); Karin Gross, Supervisory Attorney, IRS Office of Chief Counsel; and Marc L. Caine, Senior Counsel, IRS Office of Chief Counsel.

Number of Pages in PDF File: 68

Keywords: conservation easement, 170(h), charitable income tax deduction, easement donation, tax law, perpetuity, substantiation requirements, substantial compliance, qualified appraisal, qualified appraiser, Form 8283, Form 990, contemporaneous written acknowledgment, mortgage subordination

JEL Classification: H20, H50, K34, L31, Q20

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Date posted: November 8, 2012  

Suggested Citation

McLaughlin, Nancy A. and Small, Stephen J., Trying Times: Important Lessons to Be Learned from Recent Federal Tax Cases (October 2, 2012). Available at SSRN: http://ssrn.com/abstract=2171733 or http://dx.doi.org/10.2139/ssrn.2171733

Contact Information

Nancy A. McLaughlin (Contact Author)
University of Utah S.J. Quinney College of Law ( email )
332 South 1400 East, Rm 101
Salt Lake City, UT 84112-0730
United States
801-581-5944 (Phone)
801-581-6897 (Fax)

Stephen J. Small
Law Office of Stephen J. Small, Esq., P.C. ( email )
One Gateway Center, Suite 801
Newton, MA 02458
United States
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