Charles and Susan Glass v. Commissioner of Internal Revenue

EDMUNDS, District Judge.

On 1992 and 1993 tax returns, Charles and Susan Glass (“Taxpayers”) claimed charitable deductions for two conservation easements. The Commissioner of Internal Revenue (the “Commissioner”) issued a notice of deficiency. Taxpayers filed a petition in the Tax Court challenging the Commissioner’s decision. The Commissioner conceded that the 1992 and 1993 contributions met two of the three requirements for a “qualified conservation contribution” under the Internal Revenue Code (“I.R.C.”), 26 U.S.C. § 170(h)(1); i.e., that the portions of the Glass property covered by each…