On December 22, 2016, the United States Tax Court (the “Court”) issued 15 West 17^th Street LLC v. Commissioner, 147 T.C. No. 19 (2016) and addressed, a question related to the statutory construction of section 170(f)(8),[1] which governs the substantiation requirements for certain charitable contributions. The Court held that the taxpayer was not entitled to a charitable contribution deduction for its donation of a historic preservation deed of easement to a non-profit organization on the ground that the rulemaking authority delegated in subparagraph (D) is not self-executing in the absence of regulations. Therefore, the general rule set forth in subparagraph (A) requiring a contemporaneous written acknowledgment applied to the gift at issue.   Continue reading →