Energy Efficient Commercial Building Property and Section 179D: New Case Offers Guidance on Allocations of Deductions


 

Disputes will arise when Congress enacts a tax incentive, it orders the IRS to supply details via regulations, the IRS publishes Notices instead, the Notices contemplate participation by multiple parties and the liberal allocation of tax benefits among them, the IRS issues guidance over the years echoing the Notices, and then the IRS suddenly changes its tune. This is exactly what has occurred when it comes to tax deductions for expenses related to Energy Efficient Commercial Building Property. This article provides an overview of Section 179D, explains various sources of IRS guidance from the past two decades, and analyzes the newest Tax Court case on point, Johnson v. Commissioner.

Read the full article here.

About Hale E. Sheppard
HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

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