Commissioner of the Internal Revenue Service v. Dorothy Jean Simmons

National Trust for Historic Preservation and L'Enfant Trust

In November 2010, our attorneys filed an amicus brief in the US Court of Appeals for the DC Circuit on behalf of the National Trust for Historic Preservation, The L'Enfant Trust, and the Foundation for the Preservation of Historic Georgetown. The case involved an appeal by the Internal Revenue Service of the US Tax Court decision in the Simmons case, which found that a façade easement donated to The L'Enfant Trust was a qualified charitable contribution under the Internal Revenue Code. The brief sets forth legal and public policy arguments in support of tax deductions for façade easement donations. The US Court of Appeals affirmed the lower court's decision, and credited the arguments made by the donor and amici.

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