Individual Making Qualified Conservation Contribution Allowed Gift Tax Charitable Deduction

Reply to request for a ruling that a certain contribution will be a qualified conservation contribution under section 170(h) of the Internal Revenue Code, entitling the donors to a charitable deduction under section 170(c) and a gift tax deduction under section 2522.

This is in reply to a request for a ruling that a certain contribution will be a qualified conservation contribution under section 170(h) of the Internal Revenue Code (c) and a gift tax deduction under section 2522.

The Tax Court held that the taxpayer had not made a completed gift to the Forest Service, and thus no charitable contribution deduction could be claimed.

This article analyzes the Internal Revenue Code and U.S. Treasury regulations to determine if the donation of a partial interest in water rights can qualify for a tax deduction. Some donations of partial interests in water rights have already been allowed as tax deductible charitable contributions.

Following Belk v. Commissioner, the Tax Court held that the conservation easement did not qualify for a charitable deduction because there was no 'qualified property interest' as required by section 170(h)(2)(C).

A U.S. district court has sustained the IRS's disallowance of a couple's claimed charitable contribution deduction for the donation of a preservation easement on their home, because they failed to properly substantiate their claim as required by section 170 and its accompanying regulations.

Reply to request for a ruling that a certain contribution will be a qualified conservation contribution under section 170(h) of the Internal Revenue Code.

Does an easement transferred by decedent meet the requirements of section 170(f)(3)(B) of the Internal Revenue Code so that it qualifies for an estate tax charitable deduction within the meaning of section 2055(a) and (e) of the Code.

This is in reply to a request for a ruling that a proposed contribution will be a qualified conservation contribution under section 170(h) of the Internal Revenue Code.

Response to letter requesting ruling that a proposed contribution of a conservation easement will be deductible as a qualified conservation contribution under section 170(h) of the Internal Revenue Code.