Belk v. Comm'r
United States Tax Court
In 2004 Ps contributed a conservation easement on 184.627 acres of a golf course to a qualified organization. The conservation easement agreement permitted the parties, by agreement and subject to certain restrictions, to change what real property was subject to the conservation easement. Ps claimed a charitable contribution deduction on their 2004 Federal income tax return.
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In 2004 Ps contributed a conservation easement on 184.627 acres of a golf course to a qualified organization. The conservation easement agreement permitted the parties, by agreement and subject to certain restrictions, to change what real property was subject to the conservation easement. Ps claimed a charitable contribution deduction on their 2004 Federal income tax return. I.R.C. sec. 170 allows a deduction for a "qualified conservation contribution". A qualified conservation contribution requires a contribution of a qualified real property interest. I.R.C. sec. 170(h)(1)(A). A qualified…
1Opinion of the Court
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 settlement1 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 facts,…
2Cases cited17 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
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- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
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3Cited by21 opinions
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