Graev v. Commissioner
About This Legal Opinion
The Tax Court held for the IRS, finding that the cash and easement gifts were rendered conditional by the side letter, and that the possibility that the IRS would disallow the deductions was not 'so remote as to be negligible.' Tax Court upheld a 20% overvaluation penalty .
Disclaimer
These resources are provided "as is" for informational purposes only, without warranty of any kind. They do not constitute legal or professional advice and do not create an attorney-client relationship. They may not reflect current legal developments and should be adapted for your organization with qualified professional help. The Alliance is not liable for any damages arising from use of or reliance on these resources. Views in individual posts and third-party links/logos are not Alliance endorsements. The Alliance is committed to equal opportunity and does not condone unlawful discrimination.
For accreditation-related materials, please also consult the Land Trust Accreditation Commission website.