Utah is consistently recognized as one of the most charitable states in the country. Whether giving to churches, nonprofits, schools, or local communities, generosity is part of our culture. But a recent Tax Court case is a powerful reminder that the IRS doesn't give leeway to the charitable deduction requirements.

In Martin v. Commissioner (T.C. Memo. 2026-39), a Utah family donated land worth hundreds of thousands of dollars to Highland City. No one disputed that the gift was legitimate.

Yet the IRS, and ultimately the Tax Court, denied a $332,500 charitable deduction because the city's acknowledgment letter was missing one required sentence: a statement confirming whether the donors received any goods or services in exchange for the gift (or affirmatively stating that they did not).

The court reiterated that the substantiation rules under IRC § 170(f)(8) are strict, bright-line requirements. A taxpayer cannot rely on substantial compliance, good intentions, or other supporting documents to fix an incomplete acknowledgment.

For donors and advisors, the takeaway is clear:

✅ Don't assume a receipt or thank-you letter is enough.
✅ Review acknowledgment letters before filing your return.
✅ Make sure they contain every statement required by the Internal Revenue Code.

As an estate planning attorney, I often work with clients making significant charitable gifts. Cases like this are a reminder that thoughtful planning includes not only structuring the gift, but also making sure the paperwork is done correctly.