Bulletin No. 2004-28 July 12, 2004

Notice 2004–41, page 31. Charitable contributions and conservation easements. This notice informs taxpayers that the Service will, in appropriate cases, reduce or disallow deductions claimed by taxpayers under section 170 of the Code for transfers in connection with conservation easements. This notice also informs participants in these transactions that they may be subject to other adverse tax consequences, including penalties, excise taxes, and loss of tax-exempt status, as appropriate.

Notice 2004–44, page 32. Section 368(a)(1)(B). The Service is requesting public comments regarding Rev. Proc. 81–70, 1981–2 C.B. 729, which contains the guidelines for estimating the basis of stock acquired in a B reorganization.

Notice 2004–45, page 33. This notice advises taxpayers that the Service will challenge the meritless filing position of certain U.S. citizens who claim to be residents of the U.S. Virgin Islands and to have income from sources in the U.S. Virgin Islands or income effectively connected to the conduct of a trade or business in the U.S. Virgin Islands.

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