Esgar Corp. v. Comm'r
United States Tax Court
Ps granted qualified conservation easements to a qualified conservation organization in 2004, reporting noncash charitable contributions on their respective 2004 tax returns. R determined deficiencies in income tax, based in part on R's determination that Ps had overstated the value of the conservation easements. R also determined sec. 6662(a), I.R.C., accuracy-related penalties against the Holmeses and the Tempels.
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Ps granted qualified conservation easements to a qualified conservation organization in 2004, reporting noncash charitable contributions on their respective 2004 tax returns. R determined deficiencies in income tax, based in part on R's determination that Ps had overstated the value of the conservation easements. R also determined sec. 6662(a), I.R.C., accuracy-related penalties against the Holmeses and the Tempels. Held: Ps are liable for the income tax deficiencies to the extent redetermined herein as the result of overvaluing the contributed conservation easements. Held, further, the…
1Opinion of the Court
ESGAR CORPORATION, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Esgar Corp. v. Comm'r
Docket Nos. 23676-08, 23688-08, 23689-08
United States Tax Court
T.C. Memo 2012-35; 2012 Tax Ct. Memo LEXIS 32; 103 T.C.M. (CCH) 1185;
February 6, 2012, Filed
Tempel v. Comm'r, 136 T.C. 341, 2011 U.S. Tax Ct. LEXIS 14 (2011)
Decisions will be entered under Rule 155.
Ps granted qualified conservation easements to a qualified conservation organization in 2004, reporting noncash charitable contributions on their respective 2004 tax returns. R determined deficiencies in income tax, based in part…
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