Document / Legal Opinion

Simmons v. Commissioner TC Memo 2009-208

Posted 2017
Source
L’Enfant Trust
About This Legal Opinion

Tax Court rejected all of the IRS’ qualification arguments, found that the easements qualified as “contemporaneous written acknowledgements” under 170(f)(8), held that the appraisals substantially complied with the Treasury Regulations for “qualified appraisals” and reduced the allowed deductions.

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