The Tax Law of Charitable Giving, 6th Edition

CHAPTER EIGHTAdditional Aspects of Deductible Giving

• § 8.5 Interrelationship with Business Expense Deduction
• § 8.14 Abusive Tax Transactions
  • (c) Syndicated Conservation Easements

§ 8.5 INTERRELATIONSHIP WITH BUSINESS EXPENSE DEDUCTION

p. 382. Insert as second paragraph, before heading:

As a second illustration, a partnership operates a chain of supermarkets, some of which are located in a particular state. The partnership conducts a promotional program in which it sets aside the proceeds from 1 percent of its annual sales, which it pays to one or more charitable organizations. The funds are earmarked for use in projects that improve conditions in the state. The partnership makes the final determination as to which charities receive payments. The partnership advertises this program, reasonably believing that the program will generate a significant degree of name recognition and goodwill in the communities where it operates and thereby increase its revenue. As part of this program, the partnership makes a $1,000 payment to a charity. The partnership may treat the $1,000 payment as business expenses, deductible as such.^82.1

§ 8.14 ABUSIVE TAX TRANSACTIONS

(c) Syndicated Conservation Easements

p. 404, last paragraph, second and third lines. Delete parentheses and text within them.

p. 407, note 200, third line. Insert prior to closing parenthesis:

(M.D. Ga. 2020)

p. 407. Insert following second complete paragraph, before heading:

As private litigation against promoters ...