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Charitable

Tax Court – Deed of easement didn’t meet written acknowledgment rules, so no charitable deduction

Tax Court – Deed of easement didn’t meet written acknowledgment rules, so no charitable deduction

French, TC Memo 2016-53 The Tax Court has held that a deed of easement didn’t meet the charitable deduction contemporary written acknowledgement requirements of Code Sec. 170(f)(8)(B) and therefore the taxpayer didn’t qualify for a charitable deduction.  Click here for the Opinion of the Court. Background. Code Sec. 170(f)(8)(A) provides that no deduction is allowed […]

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Tax Tip – Good Records Key to Claiming Gifts to Charity

Tax Tip – Good Records Key to Claiming Gifts to Charity

Tax Time Guide: Good Records Key to Claiming Gifts to Charity IRS YouTube Videos: Charitable Contributions: English | Spanish | ASL  Exempt Organizations Select Check: English | Spanish | ASL WASHINGTON ― The Internal Revenue Service today reminded taxpayers planning to claim charitable donations to make sure they have the records they need before filing their 2015 tax returns. This is the fifth in a […]

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District Court – taxpayer that reimbursed contributor to charity could take charitable deduction

District Court – taxpayer that reimbursed contributor to charity could take charitable deduction

Green, (DC OK 2/10/2016) 117 AFTR 2d ¶ 2016-418 A district court has held that, where a partnership intended to make a charitable contribution, but, instead the contribution was made by a related corporation, and then the partnership reimbursed the corporation, the partnership was entitled to the charitable deduction. Background. Under Code Sec. 170(a), a taxpayer […]

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Court of Appeals – Courts need not accept either party’s position when valuing property

Court of Appeals – Courts need not accept either party’s position when valuing property

Palmer Ranch Holdings Ltd., (CA 11 2/5/2016) 117 AFTR 2d ¶ 2016-395 The Court of Appeals for the Eleventh Circuit has affirmed a Tax Court determination as to the highest and best use of property that was subject to an easement, but disagreed with the value that the lower court assigned to that highest and […]

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Tax Court – No charitable deduction for taxpayers who obtained appraisal but failed to include with return

Tax Court – No charitable deduction for taxpayers who obtained appraisal but failed to include with return

Gemperle, TC Memo 2016-1 The Tax Court has upheld IRS’s disallowance of a charitable contribution deduction for a conservation easement because the taxpayers, despite obtaining an appraisal, failed to include it with their return. The Court also found that the taxpayers were liable for 40% gross valuation misstatement penalties.  Click here for the Opinion of […]

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IRS to apply Code’s church audit restrictions to church employment tax inquiries, audits

IRS to apply Code’s church audit restrictions to church employment tax inquiries, audits

RS Small Business/Self Employed Division Memo “IRC section 7611 Procedures Relating to Employment Tax Examinations of Churches (Dec. 17, 2015). In a memo, IRS’s Small Business/Self Employed (SB/SE) division has changed its instructions to its examiners, telling them to apply procedures in Code Sec. 7611, which restrict IRS inquiries and examinations involving churches’ tax-exempt status […]

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IRS tries to placate fears about alternate donee reporting of $250-or-more charitable gifts

IRS tries to placate fears about alternate donee reporting of $250-or-more charitable gifts

Emailed IRS Statement. Using the unusual venue of an e-mail, IRS has sought to assure charitable organizations that proposed regs issued in September wouldn’t make mandatory changes to the way donees currently acknowledge charitable gifts of $250 or more. The proposed regs would merely implement an optional donee reporting procedure, authorized by Code Sec. 170(f)(8)(D), […]

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IRS offers tips for 2015 year-end charitable contributions

IRS offers tips for 2015 year-end charitable contributions

IR 2015-134 In a news release, IRS has reminded individuals and businesses making year-end charitable contributions, of several important tax law provisions and general substantiation requirements that they should keep in mind. Rules for clothing and household items. To be deductible, clothing and household items donated to charity must be in good used condition or better. […]

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Trust can claim charitable deduction for full value of donated appreciated real property

Trust can claim charitable deduction for full value of donated appreciated real property

Green v. U.S. (DC OK, 11/4/2015) 116 AFTR 2d ¶ 2015-5394 A district court has concluded that a trust that donated appreciated real property to charities could claim a charitable contribution deduction under Code Sec. 642(c)(1) based on the fair market value (FMV) of those properties. The trust’s deduction wasn’t limited to its adjusted basis […]

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IRS looks at deductibility of business donations to charitable and other similar organizations

IRS looks at deductibility of business donations to charitable and other similar organizations

Chief Counsel Advice 201543013 Some civic-minded businesses advertise that they will give a certain percentage of their sales proceeds to organizations devoted to a particular cause, such as environmental conservation or eradicating hunger. A new Chief Counsel Advice (CCA) examines the deductibility of such donations made by a business to a variety of such organizations. […]

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No estate charitable set-aside deduction where contribution was subject of litigation

No estate charitable set-aside deduction where contribution was subject of litigation

Estate of John D. DiMarco, TC Memo 2015-184 The Tax Court has held that an estate wasn’t entitled to a deduction under Code Sec. 642(c)(2) for an amount that it claimed was permanently set aside for two churches. The estate, which was involved in active litigation with potential heirs seeking a portion of the funds […]

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Final regs allow private foundations to rely on qualified practitioners for charitable status

Final regs allow private foundations to rely on qualified practitioners for charitable status

T.D. 9740, 09/23/2015; Reg. § 53.4942(a)-3, Reg. § 53.4945-5 IRS has issued final regs on the standards for making a good faith determination that a foreign organization is a charitable organization that is not a private foundation, so that grants made to that foreign organization may be qualifying distributions and not taxable expenditures. Under the […]

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How to meet charitable hospital financial assistance provider list requirement

How to meet charitable hospital financial assistance provider list requirement

Notice 2015-46, 2015-28 IRB In a Notice, IRS has provided guidance for how charitable hospitals should comply with the requirement that, in order to maintain charitable organization status, they provide a list that specifies which providers, e.g., doctors, are covered by the hospital’s financial assistance policy (FAP) and which are not. Background. Code Sec. 501(r)(1) provides […]

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Tax court: Preservation easement plus sale of development rights yielded no charitable deduction

Tax court: Preservation easement plus sale of development rights yielded no charitable deduction

Costello, TC Memo 2015-87 The Tax Court has held that a taxpayer could take no charitable deduction with respect to a land preservation easement that he granted to a county government as a condition for being able to sell development rights pertaining to that land. The Court found a lack of donative intent and also […]

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Tax Court – Lack of substantiation for $37,000 charitable deduction for household items

Tax Court – Lack of substantiation for $37,000 charitable deduction for household items

Kunkel, TC Memo 2015-71   The Tax Court has held, despite its having no doubt that the taxpayer donated property to a charitable organization, that none of his contributions totalling $37,315 were deductible, because he failed the charitable contribution substantiation tests. In addition, the taxpayer was liable for a Code Sec. 6662 accuracy-related penalty.  Click […]

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2015 Donations For Slain NY Police Officers’ Families May Be Deductible On 2014 Returns

2015 Donations For Slain NY Police Officers’ Families May Be Deductible On 2014 Returns

IR 2015-65 In an Information Release, IRS has announced that taxpayers who make cash contributions before April 15 to charities providing relief for the families of two slain New York City police officers can choose to claim a charitable contribution deduction on their 2014 federal income tax returns. This option is available only if the contribution is […]

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Final Regs Issued on CHNA Requirement for Charitable Hospitals

Final Regs Issued on CHNA Requirement for Charitable Hospitals

T.D. 9708, 12/29/2014; Reg. § 1.501(r)-1, Reg. § 1.501(r)-2, Reg. § 1.501(r)-3, Reg. § 1.501(r)-4, Reg. § 1.501(r)-5 , Reg. § 1.501(r)-6, Reg. § 1.501(r)-7 , Reg. § 1.6012-2, Reg. § 1.6012-3, Reg. § 1.6033-2, Reg. § 53.4959-1, Reg. § 53.6011-1 , Reg. § 53.6071-1   Click here for TD 9708, “Additional Requirements for Charitable […]

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No charitable contribution deduction allowed to creators of scholarship fund in son’s memory

No charitable contribution deduction allowed to creators of scholarship fund in son’s memory

Kalapodis, TC Memo 2014-205 The Tax Court has concluded that taxpayers, husband and wife, weren’t entitled to a charitable contribution deduction for scholarship payments made by a trust that they established as a scholarship fund and which they funded with the proceeds of life insurance on their late son. Click here for the Opinion of […]

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Poor substantiation kills charitable deduction for $27,000 of household, etc. items

Poor substantiation kills charitable deduction for $27,000 of household, etc. items

Smith, TC Memo 2014-203 The Tax Court has ruled, despite its having no doubt that the taxpayer donated property to a charitable organization, that none of taxpayer’s contributions were deductible because he failed the charitable contribution substantiation tests. Click here for the Opinion of the Court. Facts. At his Tax Court trial, Mr. Smith, the […]

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IRS Reminder: Act by 12/31/14 to Claim Extended Qualified Charitable Contribution Break

IRS Reminder: Act by 12/31/14 to Claim Extended Qualified Charitable Contribution Break

IR 2014-117   An IRS news release reminds eligible taxpayers that, thanks to the recently enacted Tax Increase Prevention Act (TIPA), they have until Wednesday, Dec. 31, 2014, to make qualified charitable distributions (QCDs) from their IRAs. Such distributions, available only to taxpayers age 70- 1/2 or older, aren’t taxable, but don’t yield a charitable deduction. […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney