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Facade easement

Court of Appeals affirms: façade easement in historic district had no value

Court of Appeals affirms: façade easement in historic district had no value

Scheidelman, (CA 2 6/18/2014) 113 AFTR 2d ¶ 2014-952. The Court of Appeals for the Second Circuit has affirmed the Tax Court’s decision that a taxpayer wasn’t entitled to a charitable deduction for a façade easement because the easement had no value. The Court found that, given the nature of the property at issue and […]

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Tax Court: pre-easement restrictions made easement worthless

Tax Court: pre-easement restrictions made easement worthless

In Kaufman v. Commissioner, TC Memo 2014-52TC Memo 2014-52, in what amounted to a battle of expert witnesses, the Tax Court sided with IRS’s expert in holding that a façade preservation easement that taxpayers granted to a preservation organization had no value because the façade was already subject to similar restrictions as a result of […]

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Facade easement didn’t qualify for charitable contribution

Facade easement didn’t qualify for charitable contribution

In 61 York Acquisition, LLC v. Commissioner,  T.C. Memo. 2013-266, the Tax Court has ruled that a partnership’s contribution of a façade easement to a qualified organization did not qualify for a charitable deduction because the easement didn’t preserve the entire exterior of the building. Facts. Partnership, the taxpayer, owned an interest in a Chicago […]

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Tax Court reverses holding that façade easement appraisal wasn’t qualified

Tax Court reverses holding that façade easement appraisal wasn’t qualified

The Tax Court, in Barry S. Friedberg and Charlotte Moss v. Commissioner, TC Memo 2013-224, based on an intervening change in the law resulting from a subsequent appellate court decision, has granted the taxpayers’ motion to reconsider its prior holding that an appraisal was not a qualified appraisal. It now concludes that the appraisal was […]

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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