U.S. Tax Court Upholds Disallowance of Charitable Contribution Deductions for Inadequate Acknowledgment

The U.S. Tax Court, in a memorandum decision, held that taxpayers were not entitled to charitable contribution carryover deductions arising from a 2016 donation of real property because they failed to satisfy the contemporaneous written acknowledgment requirements of I.R.C. §170(f)(8). Taxpayers, a married couple, claimed charitable contribution deductions for tax years 2019, 2020, and 2021 based on carryovers from a 2016 noncash charitable contribution of real property consisting of land and structures. The property was donated by an LLC owned by the taxpayers to a nonprofit academy through a quitclaim deed, with the donation valued at $4.42 million according to ...