Zarlengo v. Comm'r
United States Tax Court
Z and then spouse S sought to contribute a facade conservation easement on their property to the National Architectural Trust (Trust). Z and S obtained an appraisal claiming the value of the conservation easement to be $660,000 as of July 26, 2004. On or before September 22, 2004, Z, S, and the Trust all signed a conservation deed of easement.
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Z and then spouse S sought to contribute a facade conservation easement on their property to the National Architectural Trust (Trust). Z and S obtained an appraisal claiming the value of the conservation easement to be $660,000 as of July 26, 2004. On or before September 22, 2004, Z, S, and the Trust all signed a conservation deed of easement. However, the deed was not recorded until January 26, 2005. Z and S each claimed a charitable contribution deduction of $330,000 for the conservation easement on their separately filed 2004 tax returns. Because of applicable gross income limitations on…
1Opinion of the Court
MARCO ZARLENGO AND LINDA MCMAHON-ZARLENGO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent;
MERILYN H. SANDIN-ZARLENGO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Zarlengo v. Comm'r
Docket Nos. 3701-10, 26747-10.
United States Tax Court
T.C. Memo 2014-161; 2014 Tax Ct. Memo LEXIS 159; 108 T.C.M. (CCH) 155;
August 11, 2014, Filed
Decisions will be entered under Rule 155.
Z and then spouse S sought to contribute a facade conservation easement on their property to the National Architectural Trust (Trust). Z and S obtained an appraisal claiming the value of the conservation…
2Cases cited32 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Hernandez v. CommissionerSupreme Court of the United States · 1989
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
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