Although Judge Christian N. (“Speedy”) Weiler acknowledged that “(P)etitioners reasonably relied on Mr. L’s advice as he had been their tax accountant for some 30 years and they had no reason to question the advice he was providing,” William P. Wells and Ruth E. Wells, T. C. Memo. 2026-49, filed 6/10/26, at p. 14, (name omitted), I have little doubt Mr. L has received, or will soon receive, The Phone Call.

See my blogpost “The Phone Call,” 4/15/14.

This time it’s a busted Dixieland boarding school rather than boondockery, but it’s the usual story. The busted school operators sell to friendly parties who do a roundy-round transfer and claim a $4.42 million deduction on what they sold to the friendlies for $200K.

The carryover charitable deductions (three years’ worth) are in the IRS Leupold, and Mr. L.’s advice how to paper this is where the red dot shows.

“He just needs to write a letter on [donee] letterhead acknowledging and thanking [box-checked LLC donor] for the generous gift of the Campus property as of December 30, 2016. It would be really good if he says he understands that the Campus has a current appraised value of $4,420,000. That is all that it needs.” T. C. Memo. 2026-49, at p. 4.

As my readers face-palm and chant “Section 170(f)(8)(B)(ii),” I note Judge Speedy Weiler covers the waterfront on integration of documents to form a CWA, and what elements a CWA must contain. And no, you cannot argue that reading between the lines would let IRS figure out that no goods or services were provided; track the statutory language.

Taishoff says, whether you have 30 years’ or 30 minutes’ experience, when a million-dollar deal is on the menu look up the statute and follow it. Or be prepared for The Phone Call.