In a recent case from the Fourth Circuit Court of Appeals, Mann v. U.S., 127 AFTR 2d 2021-XXXX (4th Cir. Jan. 6, 2021), the Court determined that the donation of a house which was subject to demolition failed to satisfy two requirements under Section 170 of the Code. First, the taxpayer failed to donate the…
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After experiencing an inability to pass as a standalone bill, the Corporate Transparency Act (“Act”) now finds itself tacked to the National Defense Authorization Act for Fiscal Year 2021, being passed by both the House and Senate with veto-proof majorities, 335-78 in the House and 84-14 in the Senate.[1] Following presidential veto, the Senate voted…
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Introduction Generally, a taxpayer may deduct the fair market value of appreciated property donated to a qualified charitable organization.[1] This provision expands the benefits available to taxpayers with respect to charitable deductions. The result, in effect, is that a taxpayer may gift an appreciated asset in lieu of selling the asset, paying tax, and then…
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As of September 14, 2020, Devin Mills joins Edmondson Sage Allen, PLLC as an associate attorney. Prior to working at Edmondson Sage Allen, PLLC, Devin was an associate practicing in tax and estate planning with Baker Donelson in its Jackson, Mississippi office. Devin received his law degree from the University of Mississippi and completed his…
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Here we are coming upon the fourth anniversary of the one of the most shocking nights of our country since perhaps the Battle of Saratoga and one of the largest cash outlays by our government ever known by means of the CARES Act. On the heels of these events Democrats are setting the stage to…
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It is not uncommon for a property owner to experience a large loss on the sale of a piece of property. It is also not uncommon that an issue exists regarding character of the loss and whether the asset sold was a capital asset or a business asset used in carrying on a trade or…
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On July 1, 2020, the new Mississippi Uniform Estate Tax Apportionment Act went into effect under Sections 33-46 of S.B. 2851, replacing the old Uniform Estate Tax Apportionment Act under Title 27 Chapter 10 of the Mississippi Code. What does apportionment of estate taxes mean anyway? Apportionment of estate taxes is the determination and allocation…
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On Friday, March 26, 2020, history was made. In one fell swoop, Congress dropped $2.2 trillion to keep the United States’ economy going during the COVID-19 epidemic with the passage of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). With such a lengthy bill, many are wondering what all is contained in the…
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Conservation has been in the tax news yet again recently. Really, ever since Notice 2017-10, conservation easements, especially those of the syndicated variety, have been caught in the cross hairs of the IRS as well as the Department of Justice while also drawing the ire of a few of those in power in Congress. Most…
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In a recent case out of the U.S. District Court in Wisconsin, the Court granted a motion to reconsider its previous ruling in favor of the government (filed by the IRS) in a case involving the postmark rule. Additionally, the IRS was the recipient of some pretty strong criticism from the Court. So much so,…
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