Rajagopalan v. Commissioner
About This Legal Opinion
IRS challenged the amendment clause and valuation. The Tax Court followed Pine Mountain Preserve (affirmed by the 11th Circuit) that the amendment clause is consistent with the granted-in-perpetuity section 170(h)(2)(C). The Tax Court upheld the deduction in its entirety after a lengthy analysis.
November 2025 Update: Tax Court denied Sapp’s request for recovery of litigation costs because IRS’ litigation positions were substantially justified.
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