Document / Legal Opinion

Hoffman Properties II, L.P. v. Commissioner (6th Circuit)

Posted 2021
Author
Robert H. Levin
About This Legal Opinion

The IRS disallowed a deduction on a donation of a façade easement due to a default approval clause saying it failed to satisfy the prohibition and preservation requirement of sect 170(h)(4)(B)(i) especially because it could permit changes to the protected exterior. Sixth Circuit affirmed.

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