Scheidelman v. Commissioner of Internal Revenue (Tax Court
About This Legal Opinion
The Tax Court held that the appraisal was not a 'qualified appraisal,' there was no reasonable cause exception, no substantial compliance, the endowment is not a deductible gift and no penalties due to reasonable reliance.
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Scheidelman v. Commissioner of Internal Revenue (Respondent-
Brief filed by IRS. The Tax Court held that the appraisal was not a 'qualified appraisal,' there was no reasonable cause exception, no substantial compliance, the endowment is not a deductible gift and no penalties due to reasonable reliance.
Scheidelman v. Commissioner of Internal Revenue (Petitioner-
Brief filed in the 2nd Circuit for Petitioner Scheidelman. The Tax Court held that the appraisal was not a 'qualified appraisal,' there was no reasonable cause exception, no substantial compliance, the endowment is not a deductible gift and no penalties due to reasonable reliance.
Rothman v. Commissioner of IRS
Tax Court held that the appraisal was not a qualified appraisal because it did not contain a method and specific basis for valuation, essentially following Scheidelman
Lord v. Commissioner
The Tax Court held that the appraisal was not a qualified appraisal due to omission of several dates and FMV. The Court found these omissions significant enough so as to preclude the application of the doctrine of substantial compliance.
Scheidelman v. Commissioner of Internal Revenue (Appeals Opinion)
Opinion of the 2nd Circuit, overturning the previous ruling of the Tax Court with respect to Scheidelman v. Commissioner of Internal Revenue
Evans v. Commissioner
The taxpayer failed to meet the burden of proof on valuation so the IRS' zero valuation was sustained. The Court declined to assess the accuracy-related penalty, finding that the original appraisal was qualified, that taxpayer had reasonable cause and acted in good faith reliance on the appraiser.
Balsam Mountain Investments, LLC v. Commissioner
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).
Qualified Appraisal Checklist
This factsheet describes the components of and other considerations for a qualified appraisal.
Palmer Ranch Holdings, LTD v. Commissioner I
Tax Court largely agreed with taxpayer's appraiser but did reduce the value somewhat and found the reasonable cause exception avoided the penalty.
Brotzler v. Commissioner
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.