Legal Opinion

Browning v. Commissioner

United States Tax Court

Decided November 25, 1997No. Tax Ct. Dkt. No. 16336-94, Docket No. 20287-95Published

H county has a program to preserve farmland by purchasing development rights from landowners. Under that program, Ps conveyed an easement to the county in consideration of a cash downpayment and an installment note. Ps claimed a charitable contribution on the basis that they had made a "bargain sale" of the easement to the county.

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H county has a program to preserve farmland by purchasing development rights from landowners. Under that program, Ps conveyed an easement to the county in consideration of a cash downpayment and an installment note. Ps claimed a charitable contribution on the basis that they had made a "bargain sale" of the easement to the county. The consideration received by Ps from the county was consistent with consideration paid by the county to other participating landowners under the program. Relying on sec. 1.170A-14(h)(3)(i), Income Tax Regs., R argues that evidence of consideration paid by the…

1Opinion of the Court

CHARLES H. BROWNING, JR., AND PATRICIA L. BROWNING, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Browning v. Commissioner

Tax Ct. Dkt. No. 16336-94, Docket No. 20287-95

United States Tax Court

109 T.C. 303; 1997 U.S. Tax Ct. LEXIS 69; 109 T.C. No. 16;

November 25, 1997, Filed

Decisions will be entered for petitioners.

H county has a program to preserve farmland by purchasing development rights from landowners. Under that program, Ps conveyed an easement to the county in consideration of a cash downpayment and an installment note. Ps claimed a charitable contribution on the basis that…

2Cases cited15 opinions

  1. Olson v. United StatesSupreme Court of the United States · 1934
  2. United States v. FullerSupreme Court of the United States · 1973
  3. Harold Dejong and Marjorie J. Dejong v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
  4. Stark v. CommissionerUnited States Tax Court · 1986
  5. Simms v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1952

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