Trout Ranch, LLC v. Commissioner
Court of Appeals for the Tenth Circuit
1Opinion of the Court
ORDER AND JUDGMENT *
TERRENCE L. O’BRIEN, United States Circuit Judge.
INTRODUCTION
This appeal concerns the tax treatment of a conservation easement. The taxpayer, Trout Ranch, LLC (Trout Ranch), purchased some 450 acres of land in Gunnison County, Colorado, with the aim of developing home sites on a small segment while preserving the rest, approximately 85 percent of the property, by means of a conservation easement. Trout Ranch claimed a charitable deduction for the easement, which it valued at approximately $2.2 million. The IRS determined the easement did not reduce the value of the…
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