B. v. Belk, Jr. & Harriet C. Belk v. Commissioner

VASQUEZ, Judge:

Respondent determined deficiencies of $806,375, $784,678, and $491,239 in petitioners’ Federal income tax for 2004, 2005, and 2006, respectively. The issues for decision after partial settlement 1 are: (1) whether petitioners are entitled to a charitable contribution deduction with respect to the conservation easement they granted to Smoky Mountain National Land Trust (SMNLT); 2 and (2) if petitioners are entitled to a charitable contribution deduction, the amount of the deduction. 3

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulation of…