United States Seventh Circuit

In a suit over the denial of a tax deduction for a charitable remainder trust that had not satisfied the requirements for converting to a deductible charitable remainder "unitrust", judgment for the IRS is affirmed where the requirements for converting the trust were not unimportant or unclear, thus precluding application of the substantial compliance doctrine.

Appellate Information

• Argued 10/26/2007
• Decided 11/29/2007
• Published 11/29/2007

Judges

• POSNER, Circuit Judge., Before POSNER, FLAUM, and ROVNER, Circuit Judges.

Court

• United States Seventh Circuit

Counsel

• For Appellant:
  
• Hugh J. Graham (argued), Graham & Graham, Springfield, IL, for Petitioner-Appellant.


• For Appellees:
  
• Jonathan S. Cohen, John A. Dudeck, Jr. (argued), Department of Justice Tax Division, Appellate Section, Washington, DC, for Respondent-Appellee.