Ezel / IRS Rulings / 200947057

CCA 200947057: Corrected case name and additional theories for a conservation contribution

Number
200947057
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Qualified Conservation Contribution
Topics
Income and deductions
Code sections
§ 170, § 6110
Publicly released
November 20, 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 corrects a previously supplied case name, stating that the correct name is Cooley rather than Dooley. It gives the citation as 33 T.C. 223, 225 (1959), which concerns a qualified conservation contribution topic. The message also identifies “substance over form” and “conduit” as additional theories. The remainder of the message is redacted.

Ruling snapshot

  • Question: What case name and additional theories should be considered in the conservation-contribution analysis?
  • Outcome: Advice given
  • Key authorities: IRC § 170; Cooley v. Commissioner, 33 T.C. 223 (1959)

Full text (IRS public release)

ID: CCA-721236-09 Number: 200947057
Release Date: 11/20/2009
Office: ----------------
UILC: 170.14-00

From: --------------
Sent: Thursday July 2, 2009 12:36 PM
To: ----------------
Cc: -------------------
Subject: Yesterday’s conversation

Cooley, not Dooley, sorry I gave you the wrong case name. Cite is 33 tc 223, 225 (1959). Additional
theories are "substance over form" and "conduit". -------------------------------------------------------------------------
-----------------------------------------------------------------------------------

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