IRS Penalty Approval Process Applies to Partnerships, Court Says

The US Tax Court said Tuesday that the IRS correctly complied with managerial approval requirements to levy penalties on a partnership over a denied $24.6 million charitable contribution tax deduction.

The court granted a partial motion for summary judgment for the IRS against Tanyard Farms LLC, which claimed a charitable contribution deduction for a conservation easement in 2017 after it donated development rights to 138 acres in Alabama to the Atlantic Coast Conservancy. The partnership, which has contested the disallowance, also argued that the IRS acted improperly in having a supervisor approve penalties against it in compliance with the procedural ...