Abstract
Observing that “[f]orever is a really long time — no less so in tax law” and “forever really means forever,” the US Court of Appeals for the Sixth Circuit, by opinion dated April 14, ruled that a donor of a facade easement is not entitled to a charitable contribution deduction for its gift because the contribution agreement accords the donee a 45‐day window in which to prevent certain changes to the facade or airspace (Hoffman Properties II, LP v. Commissioner).
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