Email Chief Counsel Advice

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Richard Fox analyzes a recent CCA which points to a substance over form issue on a complex charitable transaction. Caution to overly aggressive planners.

Responding to a request for Chief Counsel Advice, the IRS has advised the location of a substantial portion of donated real property within the boundaries of a national park results in a restriction on the property's highest and best use as a mineral property, and...


In Email Chief Counsel Advice, the IRS has stated that so long as property qualifies for a charitable deduction, there is no reasonable cause/good faith exception with respect to the 40% gross valuation penalty. 

22 Feb 2011 | Email Chief Counsel Advice | National Publication | News story | 1 comments
In e-mail Chief Counsel Advice, the IRS discusses the implications of donating property to charity prior to the implementation of a tax lien and whether such lien attaches to the donated property.
The Treasury's Office of Associate Chief Counsel has responded to the question of whether a taxpayer is subject to federal income tax if the taxpayer satisfied a legally binding personal pledge to a charity with a qualified charitable distribution from an individual...
In e-mail chief counsel advice, the IRS has confirmed that in cases where a qualified appraisal must be performed to substantiate the value of a taxpayer's charitable contribution, the appraiser rather than the appraisal firm must sign both the appraisal and the donor'...
The Service has issued Email Chief Counsel Advice in which it concludes that a corporation that is a partner in a partnership can take a deduction for a charitable contribution made by the partnership as though the C corporation actually made the contribution from its...
In emailed Chief Counsel Advice pursuant to a pending case, the IRS reviews the contemporaneous written acknowledgment requirements for gifts of conservation easements under section 170(f)(8)(A).
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Define: Email Chief Counsel Advice

Chief Counsel Advice (CCA) are written advice or instructions prepared by the Office of Chief Counsel and issued to field or service center employees of the IRS or Office of Chief Counsel.