Quid Pro Quo Donations Scrutinized by IRS

The Tax Court recently issued a tough lesson to taxpayers in its Seventeen Seventy Sherman Street, LLC  (TC Memo 2014-124) decision, in ruling that a taxpayer received two items of property in return for its contribution of an easement, but failed to consider the value of all of the property received.  The result?  No deduction whatsoever with respect to the donated easement!  Failure to value all of the consideration received led to the conclusion that failure to prove the fair market value of the easements exceeded the value of the consideration received in return!