Tuesday, August 27, 2013
Whitehouse Hotel LP is appealing a recent U.S. Tax Court valuation of a historic façade conservation easement, which Whitehouse granted to preserve the façade of the Maison Blanche building in New Orleans.
Whitehouse valued its donation at $7.5 million, but the Tax Court decided to adopt the much lower $1.8 million valuation by the IRS because the hotel was not open. This decision will impose a 40 percent penalty, which Whitehouse seeks to avoid in its appeal to the U.S. Court of Appeals for the Fifth Circuit.
See Daily Tax Report, IRS: Facade Conservation Easement Valuation Improper if Hotel not Open, Bloomberg BNA, Aug. 21, 2013.