The article examines the legislation that regulates tax deductions in the field of operations with real estate. Legal conditions for granting tax deductions are framed by combination of tax legislation (Subparagraph 1, Para 1 of Article 220 of the Tax Code of the Russian Federation, hereinafter referred to as the RF Tax Code) and land legislation (Article 11.4 of the Land Code of the Russian Federation, hereinafter referred to as the RF Land Code), as well as by regulations on registering operations with real estate (Para 5, Article 12 of the Federal Law No 122-FZ). As a whole, the said regulations do not establish a uniformed approach concerning subdivisionand settling the commencement date of the term of limitation for exercising the right to receive tax deductions. The author considers collision of the two juridical dates: the date of origin of land ownership and the date of issuing the land lot certificate in case of the land subdivision on the initiative of the owner. It resulted from ambiguities inherent in the legislation. Due to the stated collision there emergecontradictory legal practices with ensuing infringement of civil rights. On the basis of the presented research, the author offers to declare Subparagraph 1, Para 1 of Article 220 of the RF Tax Code unconstitutional.
