Kaufman v. Comm’r of Internal Revenue, No. 14-1863 (1st Cir. 2015)
Annotate this CaseTaxpayers claimed a $220,800 charitable deduction on their 2003 and 2004 returns that corresponded to the purported value of a historic preservation facade easement on their Boston home, which they donated to the Trust of Architectural Easements. The Commissioner of Internal Revenue disallowed the deduction. The Tax Court found that the actual value of the easement was zero and that Taxpayers were liable under applicable IRS regulations for a forty percent accuracy-related penalty for making a gross valuation misstatement. The First Circuit affirmed, holding (1) the Tax Court’s finding that Taxpayers were liable for accuracy-related penalties was sound as a legal matter and not clearly erroneous as a factual matter; and (2) Taxpayers' second argument on appeal was waived.
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