Lawrence G. & Lorna Graev v. Commissioner

140 T.C. No. 17

UNITED STATES TAX COURT LAWRENCE G. GRAEV AND LORNA GRAEV, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 30638-08. Filed June 24, 2013. Petitioner husband (“P-H”) contributed cash and a conservation easement to N, a charitable organization. Before the contribution, N at P-H’s request issued to P-H a side letter which promised that, in the event R disallows Ps’ charitable contribution deductions, N “will promptly refund your entire cash endowment contribution and join with you to immediately remove the facade conservation easement from the property’s…