The failure to list the cost basis of a remainder interest in real estate on the Form 8283 claiming a charitable contribution deduction has caused the Tax Court to disallow entirely a claimed deduction of more than $33 million. The Court has strictly interpreted the substantiation requirements without directly having to challenge the valuation. In a complicated real estate financing transaction, a limited liability company called RERI Holdings I acquired a remainder interest in real estate that was subject to a triple net lease to AT&T. The remainder interest took effect after another owner owned the property for a term of years generally covering the AT&T lease which offered a...