Victory for Conservation Easement Tax Deduction

A Tax Court decision denying a deduction for qualified conservation contribution to a limited liability company (LLC) was vacated and remanded by the 11th Circuit. The taxpayer developed and operated a golf club and had claimed a charitable deduction for donating a conservation easement over property that included a private golf course and undeveloped land.

The taxpayer argued that the word "significant" used in Reg. §1.170A-14(d)(3)(i) impermissibly departed from the conservation purpose requirement set out in Code Sec. 170. Further, the conservation easements across golf course qualified for a deduction because they met the otherwise-applicable standards. Moreover, the Tax Court’s implicit finding that the LLC did not contribute the easement "for the protection of a relatively natural habitat of fish, wildlife, or plants, or similar ecosystem" was based on erroneous finding of fact and was wrong as a matter of law.

In addition, the land still met the "rare, endangered, or threatened, or species" requirement because the land contained 61 species of birds on protected lists, as testified by the taxpayer’s and IRS’s experts. Finally, the appeals court held that the easement did preserve the scenic enjoyment of the public because the 10-foot river banks only blocked the view of the golf course, not the trees and wetlands.

Vacating and remanding the Tax Court, 116 TCM 262, Dec. 61,260(M), TC Memo. 2018-146.

Champions Retreat Golf Founders, LLC, CA-11

Wilson Tax Law Group APLC (www.wilsontaxlaw.com) is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense. The firm was founded in 2014 by Joseph P. Wilson, a former Federal tax prosecutor, trial attorney for the IRS and trial attorney for the Franchise Tax Board.For further information, or to arrange a consultation, please contact:

Wilson Tax Law Group, APLC

Newport Beach and Yorba Linda, California

Tel: 949-397-2292 (Newport Office)

Tel: 714-463-4430 (Yorba Linda Office)

Victory for Conservation Easement Tax Deduction

A Tax Court decision denying a deduction for qualified conservation contribution to a limited liability company (LLC) was vacated and remanded by the 11th Circuit. The taxpayer developed and operated a golf club and had claimed a charitable deduction for donating a conservation easement over property that included a private golf course and undeveloped land.

The taxpayer argued that the word "significant" used in Reg. §1.170A-14(d)(3)(i) impermissibly departed from the conservation purpose requirement set out in Code Sec. 170. Further, the conservation easements across golf course qualified for a deduction because they met the otherwise-applicable standards. Moreover, the Tax Court’s implicit finding that the LLC did not contribute the easement "for the protection of a relatively natural habitat of fish, wildlife, or plants, or similar ecosystem" was based on erroneous finding of fact and was wrong as a matter of law.

In addition, the land still met the "rare, endangered, or threatened, or species" requirement because the land contained 61 species of birds on protected lists, as testified by the taxpayer’s and IRS’s experts. Finally, the appeals court held that the easement did preserve the scenic enjoyment of the public because the 10-foot river banks only blocked the view of the golf course, not the trees and wetlands.

Vacating and remanding the Tax Court, 116 TCM 262, Dec. 61,260(M), TC Memo. 2018-146.

Champions Retreat Golf Founders, LLC, CA-11

Wilson Tax Law Group APLC (www.wilsontaxlaw.com) is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense. The firm was founded in 2014 by Joseph P. Wilson, a former Federal tax prosecutor, trial attorney for the IRS and trial attorney for the Franchise Tax Board.For further information, or to arrange a consultation, please contact:

Wilson Tax Law Group, APLC

Newport Beach and Yorba Linda, California

Tel: 949-397-2292 (Newport Office)

Tel: 714-463-4430 (Yorba Linda Office)

Wilson Tax Law Group Receives 2020 Best of Newport Beach Award

Press Release

FOR IMMEDIATE RELEASE

Newport Beach Award Program Honors the Achievement

NEWPORT BEACH May 7, 2020 -- Wilson Tax Law Group has been selected for the 2020 Best of Newport Beach Award in the Professional Services category by the Newport Beach Award Program.

Each year, the Newport Beach Award Program identifies companies that we believe have achieved exceptional marketing success in their local community and business category. These are local companies that enhance the positive image of small business through service to their customers and our community. These exceptional companies help make the Newport Beach area a great place to live, work and play.

Various sources of information were gathered and analyzed to choose the winners in each category. The 2020 Newport Beach Award Program focuses on quality, not quantity. Winners are determined based on the information gathered both internally by the Newport Beach Award Program and data provided by third parties.

About Newport Beach Award Program

The Newport Beach Award Program is an annual awards program honoring the achievements and accomplishments of local businesses throughout the Newport Beach area. Recognition is given to those companies that have shown the ability to use their best practices and implemented programs to generate competitive advantages and long-term value.

The Newport Beach Award Program was established to recognize the best of local businesses in our community. Our organization works exclusively with local business owners, trade groups, professional associations and other business advertising and marketing groups. Our mission is to recognize the small business community's contributions to the U.S. economy.

SOURCE: Newport Beach Award Program

Media Relations
Email: info@wilsontaxlaw.com
URL: https://www.wilsontaxlaw.com

Wilson Tax Law Group APLC (www.wilsontaxlaw.com) is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense. The firm was founded in 2014 by Joseph P. Wilson, a former Federal tax prosecutor, trial attorney for the IRS and trial attorney for the Franchise Tax Board.For further information, or to arrange a consultation, please contact:

Wilson Tax Law Group, APLC

Newport Beach and Yorba Linda, California

Tel: 949-397-2292 (Newport Office)

Tel: 714-463-4430 (Yorba Linda Office)

Wilson Tax Law Group Receives 2020 Best of Newport Beach Award

Press Release

FOR IMMEDIATE RELEASE

Newport Beach Award Program Honors the Achievement

NEWPORT BEACH May 7, 2020 -- Wilson Tax Law Group has been selected for the 2020 Best of Newport Beach Award in the Professional Services category by the Newport Beach Award Program.

Each year, the Newport Beach Award Program identifies companies that we believe have achieved exceptional marketing success in their local community and business category. These are local companies that enhance the positive image of small business through service to their customers and our community. These exceptional companies help make the Newport Beach area a great place to live, work and play.

Various sources of information were gathered and analyzed to choose the winners in each category. The 2020 Newport Beach Award Program focuses on quality, not quantity. Winners are determined based on the information gathered both internally by the Newport Beach Award Program and data provided by third parties.

About Newport Beach Award Program

The Newport Beach Award Program is an annual awards program honoring the achievements and accomplishments of local businesses throughout the Newport Beach area. Recognition is given to those companies that have shown the ability to use their best practices and implemented programs to generate competitive advantages and long-term value.

The Newport Beach Award Program was established to recognize the best of local businesses in our community. Our organization works exclusively with local business owners, trade groups, professional associations and other business advertising and marketing groups. Our mission is to recognize the small business community's contributions to the U.S. economy.

SOURCE: Newport Beach Award Program

Media Relations
Email: info@wilsontaxlaw.com
URL: https://www.wilsontaxlaw.com

Wilson Tax Law Group APLC (www.wilsontaxlaw.com) is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense. The firm was founded in 2014 by Joseph P. Wilson, a former Federal tax prosecutor, trial attorney for the IRS and trial attorney for the Franchise Tax Board.For further information, or to arrange a consultation, please contact:

Wilson Tax Law Group, APLC

Newport Beach and Yorba Linda, California

Tel: 949-397-2292 (Newport Office)

Tel: 714-463-4430 (Yorba Linda Office)

Wilson Tax Law Group Receives 2020 Best of Newport Beach Award

Press Release

FOR IMMEDIATE RELEASE

Newport Beach Award Program Honors the Achievement

NEWPORT BEACH May 7, 2020 -- Wilson Tax Law Group has been selected for the 2020 Best of Newport Beach Award in the Professional Services category by the Newport Beach Award Program.

Each year, the Newport Beach Award Program identifies companies that we believe have achieved exceptional marketing success in their local community and business category. These are local companies that enhance the positive image of small business through service to their customers and our community. These exceptional companies help make the Newport Beach area a great place to live, work and play.

Various sources of information were gathered and analyzed to choose the winners in each category. The 2020 Newport Beach Award Program focuses on quality, not quantity. Winners are determined based on the information gathered both internally by the Newport Beach Award Program and data provided by third parties.

About Newport Beach Award Program

The Newport Beach Award Program is an annual awards program honoring the achievements and accomplishments of local businesses throughout the Newport Beach area. Recognition is given to those companies that have shown the ability to use their best practices and implemented programs to generate competitive advantages and long-term value.

The Newport Beach Award Program was established to recognize the best of local businesses in our community. Our organization works exclusively with local business owners, trade groups, professional associations and other business advertising and marketing groups. Our mission is to recognize the small business community's contributions to the U.S. economy.

SOURCE: Newport Beach Award Program

Media Relations
Email: info@wilsontaxlaw.com
URL: https://www.wilsontaxlaw.com

Wilson Tax Law Group APLC (www.wilsontaxlaw.com) is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense. The firm was founded in 2014 by Joseph P. Wilson, a former Federal tax prosecutor, trial attorney for the IRS and trial attorney for the Franchise Tax Board.For further information, or to arrange a consultation, please contact:

Wilson Tax Law Group, APLC

Newport Beach and Yorba Linda, California

Tel: 949-397-2292 (Newport Office)

Tel: 714-463-4430 (Yorba Linda Office)

Wilson Tax Law Group Receives 2020 Best of Newport Beach Award

Press Release

FOR IMMEDIATE RELEASE

Newport Beach Award Program Honors the Achievement

NEWPORT BEACH May 7, 2020 -- Wilson Tax Law Group has been selected for the 2020 Best of Newport Beach Award in the Professional Services category by the Newport Beach Award Program.

Each year, the Newport Beach Award Program identifies companies that we believe have achieved exceptional marketing success in their local community and business category. These are local companies that enhance the positive image of small business through service to their customers and our community. These exceptional companies help make the Newport Beach area a great place to live, work and play.

Various sources of information were gathered and analyzed to choose the winners in each category. The 2020 Newport Beach Award Program focuses on quality, not quantity. Winners are determined based on the information gathered both internally by the Newport Beach Award Program and data provided by third parties.

About Newport Beach Award Program

The Newport Beach Award Program is an annual awards program honoring the achievements and accomplishments of local businesses throughout the Newport Beach area. Recognition is given to those companies that have shown the ability to use their best practices and implemented programs to generate competitive advantages and long-term value.

The Newport Beach Award Program was established to recognize the best of local businesses in our community. Our organization works exclusively with local business owners, trade groups, professional associations and other business advertising and marketing groups. Our mission is to recognize the small business community's contributions to the U.S. economy.

SOURCE: Newport Beach Award Program

Media Relations
Email: info@wilsontaxlaw.com
URL: https://www.wilsontaxlaw.com

Wilson Tax Law Group APLC (www.wilsontaxlaw.com) is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense. The firm was founded in 2014 by Joseph P. Wilson, a former Federal tax prosecutor, trial attorney for the IRS and trial attorney for the Franchise Tax Board.For further information, or to arrange a consultation, please contact:

Wilson Tax Law Group, APLC

Newport Beach and Yorba Linda, California

Tel: 949-397-2292 (Newport Office)

Tel: 714-463-4430 (Yorba Linda Office)

IRS provides tax relief through increased flexibility for taxpayers in section 125 cafeteria plans

May 12, 2020

WASHINGTON — The Internal Revenue Service today released guidance to allow temporary changes to section 125 cafeteria plans. These changes extend the claims period for health flexible spending arrangements (FSAs) and dependent care assistance programs and allow taxpayers to make mid-year changes.

The guidance issued today addresses unanticipated changes in expenses because of the 2019 Novel Coronavirus (COVID-19) pandemic and provides that previously provided temporary relief for high deductible health plans may be applied retroactively to January 1, 2020, and it also increases for inflation the $500 permitted carryover amount for health FSAs to $550.

Notice 2020-29 (PDF) provides greater flexibility for taxpayers by:

• extending claims periods for taxpayers to apply unused amounts remaining in a health FSA or dependent care assistance program for expenses incurred for those same qualified benefits through December 31, 2020.
• expanding the ability of taxpayers to make mid-year elections for health coverage, health FSAs, and dependent care assistance programs, allowing them to respond to changes in needs as a result of the COVID-19 pandemic.
• applying earlier relief for high deductible health plans to cover expenses related to COVID-19, and a temporary exemption for telehealth services retroactively to January 1, 2020.

Notice 2020-33 (PDF) responds to Executive Order 13877, which directs the Secretary of the Treasury to "issue guidance to increase the amount of funds that can carry over without penalty at the end of the year for flexible spending arrangements." The notice increases the limit for unused health FSA carryover amounts from $500, to a maximum of $550, as adjusted annually for inflation.

Wilson Tax Law Group APLC (www.wilsontaxlaw.com) is a boutique Orange County tax controversy law firm that specializes in representation of individuals and businesses before federal and state tax authorities with audits, appeals, FBAR, offshore compliance, litigation and criminal defense. The firm was founded by Joseph P. Wilson, a former Federal tax prosecutor, trial attorney for the IRS and trial attorney for the Franchise Tax Board.

For further information, or to arrange a consultation, please contact:

Wilson Tax Law Group, APLC

Newport Beach and Yorba Linda, California

Tel: 949-397-2292 (Newport Office)

Tel: 714-463-4430 (Yorba Linda Office)