Document / Legal Opinion

Kumar v. Commissioner

Posted March 8, 2021
Author
Robert H. Levin
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.