The Canary in the Charity Mineshaft

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By: Adam Aptowitzer We recently argued a case in Tax Court which may be of interest to the community of tax advisors and directors of charities. The case was somewhat unique because of its precedent-setting potential for both the tax planner and tax preparer subsections of the Third Party Civil Penalty rules in s.163.2. The case involves a family law lawyer who signed an opinion letter indicating, as is usual, that she had reviewed the law and facts underlying a particular tax donation shelter. The…

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