Field Service Advice

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In Field Service Advice 1999-951, the Service held that a wholly- owned subsidiary was not entitled to a charitable contribution deduction for its donation of an option to purchase real property.
In FSA 1999-923, the IRS advised that although a surviving spouse's initial transfer of stock from a qualified terminable interest property ("QTIP") trust to the charitable remainder beneficiary of the QTIP was a non-qualified split interest transfer for gift tax...
In an undated Field Service Advice, the IRS holds that a contribution of a facade easement in real property, which does not otherwise qualify as a certified historic structure, qualifies for deduction as an open space easement based on the fact the Gift Deed prohibits...
In apparently related FSA's (FSA 1999-1193 and FSA 1999-1172), the Service (i) disallowed an income tax deduction for a payment from the estate's income to an entity which was not a qualified charity, and (ii) held that the estate does not qualify for a charitable...
In FSA 1999-1174, the National Office of the Service held that an estate tax charitable deduction should be denied because (i) the decedent did not have a primarily charitable intent, but rather intended the estate's residue to pass to a particular entity in all events...
In Field Service Advice 200022005, the IRS recommended rejection of a proposed settlement agreement involving the invasion of a charitable remainder trust to pay the donor's federal tax liability.
In Field Service Advice 1995-4, released today, the Service advised that a grocery chain could not take a charitable income tax deduction equal to the full retail price of fresh bread for donations of four-day old bread to food banks.
In field service advice, the IRS has concluded it needs more information to determine whether taxpayers may deduct a contribution of a portion of their cooperative housing shares and a proprietary lease to rent their cooperative apartment to a public charity. This is...
In field service advice, the IRS has determined that further factual development is necessary to determine if a company is entitled to deduct the fair market value of contract rights given to a charity.

The IRS has issued Field Attorney Advice that concludes a business cannot deduct contributions of food inventory because it failed to attach properly completed Form 8283 to its tax return and failed to properly value its donations.

In FSA 1999-1070, the Service, quoting Hernandez v. Commissioner, 490 U.S. 680 (1989), held that tuition payments to a religious school are not deductible under section 170 of the Code because the Taxpayers received a substantial benefit on account of the payments.
In a recently-released 1992 Field Service Advice memorandum, the IRS and case rulings present inconsistent positions for valuing Rule 144 stock at death.
Can a simple a trust whose governing instrument does not authorize the trustee to make charitable contributions claim a charitable deduction for its distributive share of a charitable contribution made by a partnership, in which the trust is a partner? In field service...
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Define: Field Service Advice

Field Service Advice (FSA) is correspondence from the IRS National Office to a revenue agent for the purpose of confirming a preexisting IRS position to the facts in a particular case. An FSA does not act as a final determination; thus, a revenue agent need not follow it if the taxpayer produces more compelling arguments in support of a contrary position.