In Balsam Mountain Investments, LLC, the Tax Court took a very restrictive view of what qualifies as a “qualified real property interest” under Section 170(h)(2)(C), in granting summary judgment in favor of the IRS disallowing a charitable contribution deduction for a conservation easement. In 2003, Balsam Mountain Investments, LLC executed a perpetual conservation easement agreement […]
Lynn Hinson, a shareholder in Dean Mead’s litigation practice, authored the article titled, “Can a Pre-Petition State Tax Lien Foreclosure Be Avoided as a Fraudulent Transfer?” The article was published in the American Bar Association Section of Litigation Bankruptcy and Insolvency – News & Developments on June 12, 2014. His article may be viewed here: Can a Pre-Petition […]
Dean Mead shareholder and Chair of the firm’s Tax Department, Stephen Looney, authored the article “Camp Proposal on Tax Reform Contains Many Changes and Surprises,” published in the May 2014 edition of Tampa Bay Medical News. The article may be viewed via the following link: Camp Proposal on Tax Reform. This article was reproduced with permission from Tampa Bay […]
In Shea Homes, Inc., et al. v. Comm’r, 142 TC 3 (2014), the Tax Court held that the taxpayers (three related real estate development companies) correctly applied the completed contract method of accounting to their home construction contracts by their interpretation of the “subject matter of the contract” as not only including the houses, […]
Steve Looney, chair of Dean Mead’s Tax department, is quoted in an article titled, “Big tax bills could hit underwater owners” in the December 18, 2013 edition of the Orlando Sentinel. The article about the Mortgage Forgiveness Debt Relief Act expiring is provided here: http://www.orlandosentinel.com/business/os-mortgage-debt-forgiveness-20131213,0,3353972.story.
In Morehouse, the Tax Court held that the payments received by the taxpayers from the United States Department of Agriculture (USDA) Conservation Reserve Program (CRP) constituted self-employment income subject to the self-employment tax imposed under Section 1401. The taxpayer owned a number of acres of land in South Dakota, which he did not personally farm […]
Please note: This Tax Tip column will be published in the September–October 2013 issue of The Journal of Passthrough Entities, a publication of Wolters Kluwer Tax and Accounting. Introduction: On May 9, 2013, a Technical Advice Memorandum1 (the “TAM”) was issued with respect to a community development district (“CDD”) in Florida. Although the CDD and the developer that was […]
Charles H. Egerton and Christine L. Weingart have had an article published in the May-June 2013 Journal of Passthrough Entities entitled Options to Acquire Real Estate: When Will They Not Be Respected as “Options” for Tax Purposes?