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Appeals Court affirms denial of $33 million gift deduction

Appeals Court affirms denial of $33 million gift deduction

Appeals Court affirms denial of $33 million gift deduction

The District of Columbia Circuit Court of Appeals has affirmed a Tax Court decision denying a charitable contribution deduction of $33 million because the taxpayer didn’t include the cost basis and date of acquisition of the donated property on the Form 8283 claiming the deduction. ( See Nonprofit Issues ® , May 2017 ) The Court of Appeals said it “should be very reluctant to set to naught [the information requirement] that Congress deemed essential.” The case arises from a complex real estate transaction in which RERI, a limited liability company, acquired a remainder interest in property subject to a long-term lease with AT&T. It paid $2,950,000 for the interest in March 2002, and...

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