Green v. United States, Trust Cannot Deduct Unrealized Gain on Property Contributed to Charity

In Mart D. Green v. United States, (CA 10, Jan. 12, 2018), the Tenth Circuit, reversing a district court,held that Code Sec. 642(c)(1), which allows trusts a deduction “without limitation” for any amount of gross income paid for a charitable purpose, does not allow a trust a charitable deduction for the excess of fair market value over adjusted basis of property contributed to a charity, where the property had been purchased by the trust with the trust’s gross income.

See full opinion in Mart D. Green v. United States, (CA 10, Jan. 12, 2018) by clicking here. 

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.