Ezel / IRS Rulings / 200944043

CCA 200944043: Facade easement cases need training under the post-PPA rules

Number
200944043
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Qualified Conservation Contribution
Topics
Income and deductions
Code sections
§ 170
Ruling dated
July 24, 2009
Publicly released
October 30, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

This Chief Counsel Advice reports on a memorandum concerning a motion for summary judgment in a docketed case involving a facade easement donated in the second half of 2006. The Advice states that the case appears to be the first litigated facade-easement case affected by the Pension Protection Act. It notes that the post-PPA rules for facade easements differ significantly from prior law and have multiple effective dates. The author recommends new training for agents handling facade-easement cases covered by the PPA and offers to assist.

Ruling snapshot

  • Question: Should the IRS provide additional training for agents handling facade-easement cases covered by the Pension Protection Act?
  • Outcome: Advice given
  • Key authorities: IRC § 170; Pension Protection Act rules for facade easements

Full text (IRS public release)

ID: CCA-724164-09 Number: 200944043
Release Date: 10/30/2009
Office: ----------------
UILC: 170.14-00

From: --------------
Sent: Friday, July 24, 2009 4:45
To: ------------------------------------------------
Cc: ----------------------------------------
Subject: Façade easement made in 2006

--------- and I just worked on a memorandum in connection with a motion for summary judgment in a docketed case relating to a facade easement donated in the second half of 2006. I believe it is the first litigated facade easement case impacted by the PPA. The rules for facade easements subject to the PPA are significantly different from the rules for facade easements under prior law and these PPA rules are challenging to navigate, particularly because of a number of different effective dates.

I suggest some sort of new training for agents working facade easement cases covered by the PPA. I would be happy to help out.

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