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Charitable Deductions For Rail-Trail Conversions: Reconciling The Partial Interest Rule And The National Trails System Act, Scott Andrew Bowman, Danaya C. Wright
Charitable Deductions For Rail-Trail Conversions: Reconciling The Partial Interest Rule And The National Trails System Act, Scott Andrew Bowman, Danaya C. Wright
UF Law Faculty Publications
This Article examines an undeveloped legal topic at the intersection of tax law and real property law: charitable deductions from income tax liability for donations of railroad corridors that are to be converted into recreational trails. The very popular rails-to-trails program assists in the conversion of abandoned railroad corridors into hiking and biking trails. However, the legal questions surrounding the property rights of these corridors have been complex and highly litigated. In 1983, Congress amended the National Trails System Act to provide a mechanism for facilitating these conversions, a process called railbanking. In essence, a railroad transfers its real property …
Random Thoughts On Applying Judicial Doctrines To Interpret The Internal Revenue Code, Martin J. Mcmahon Jr.
Random Thoughts On Applying Judicial Doctrines To Interpret The Internal Revenue Code, Martin J. Mcmahon Jr.
UF Law Faculty Publications
From the symposium "Business Purpose, Economic Substance, and Corporate Tax Shelters" .
Recent Irs Letter Ruling Increases Opportunities For Exempt Organizations To Use Llcs, Monica Gianni
Recent Irs Letter Ruling Increases Opportunities For Exempt Organizations To Use Llcs, Monica Gianni
UF Law Faculty Publications
Monica Gianni discusses how the IRS’s analysis of a private operating foundation using an LLC in LTR 9834033 indicates the IRS’s approach to LLCs with exempt organization members.