One of the longstanding “rules of thumb” of tax research is to be careful not to rely upon a single court decision that seems to be an “outlier,” especially when it comes from a U.S. District Court which is a court that does not specialize in tax law cases. This turned out to be true in the case of Green v. United States where a decision from an Oklahoma District Court was reversed on appeal by the Tenth Circuit Court of Appeals (Case No. 16-6371).
We had covered the District Court decision on the Current Federal Tax Developments website when the opinion was published in November of 2015. The IRS had several objections, including whether any deduction should be allowed. But on appeal the IRS limited its objection to the amount of the contribution, not whether a contribution deduction should be allowed to the taxpayer.
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