Non-Cash Charitable Contribution Deductions: IRC Requirements, Strategies to Maximize the Tax Benefits

Ms. Gross has spent over 30 years at the IRS Office of the Chief Counsel specializing in tax rules for charitable giving, including reporting (Form 8283), substantiation, and appraisal requirements. While working at the IRS Office of Chief Counsel, she was responsible for written guidance on charitable contributions and helped establish litigating positions for the National Office, the Small Business and Self-Employed Division, and the Litigation and Advisory Division. Ms. Gross participated in formal review of the Treasury regulations on qualified appraisals for charitable contribution deductions. She trained IRS revenue agents and attorneys nationwide on audit and litigation issues related to charitable contributions, and she was a trusted advisor to IRS Counsel litigators and revenue agents on handling abusive charitable contribution transactions. For many years, Ms. Gross was a regular speaker on behalf of the IRS on tax topics related to personal property donations, including donations of art, and real property donations, including donations of conservation easements and fee interests. She also guest lectured, on a regular basis, at several leading law schools.  

Ms. Tyson has 25 years of experience practicing tax law, which began as a student-attorney in a federal tax clinic. She served for 2 years as a U.S. Tax Court law clerk and subsequently practiced law as an attorney in a multinational law firm, advising on employee benefits, tax, and corporate matters. In 2006, Ms. Tyson joined the Internal Revenue Service (IRS) Office of Chief Counsel. There, she was promoted to Senior Counsel and Supervisory Attorney. While with the IRS Office of Chief Counsel, Ms. Tyson was repeatedly recognized, both individually and as a team member, for making outstanding contributions. In 2022, she was named “Attorney of the Year” among all field attorneys in the IRS, nationwide. In Ms. Tyson's cases, the amounts at issue ranged from several thousand dollars to more than a billion dollars. She successfully litigated cases on behalf of the IRS in the U.S. Tax Court and advised on significant refund cases litigated by the U.S. Department of Justice in U.S. District Courts and the U.S. Court of Federal Claims. For over a decade, Ms. Tyson served as a “subject matter expert” for civil tax penalties within the IRS Office of Chief Counsel for the IRS’s Large Business & International Division. For more than five years, she advised revenue agents and attorneys nationwide regarding tax issues associated with charitable giving and advised leadership in both the IRS and the IRS Office of Chief Counsel regarding these issues. Ms. Tyson also taught scores of training sessions to revenue agents and IRS attorneys nationwide about civil penalties and conservation easements. She received multiple awards, both individually and as a team member, for her contributions.