Herman v. Comm'r
United States Tax Court
P owned approximately 22,000 square feet (six stories) of unused development rights over a "certified historic structure" within the meaning of I.R.C. sec. 170(h)(4)(B). In 2003 P contributed to a charitable organization a conservation easement that restricted the development of 10,000 unspecified square feet of those unused development rights.
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P owned approximately 22,000 square feet (six stories) of unused development rights over a "certified historic structure" within the meaning of I.R.C. sec. 170(h)(4)(B). In 2003 P contributed to a charitable organization a conservation easement that restricted the development of 10,000 unspecified square feet of those unused development rights. P claimed on his tax return a deduction for the charitable contribution of a qualified conservation easement under I.R.C. sec. 170(h)(1). R disallowed the deduction and determined a deficiency and an accompanying accuracy-related penalty under I.R.C.…
1Opinion of the Court
J. MAURICE HERMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Herman v. Comm'r
No. 14005-07
United States Tax Court
T.C. Memo 2009-205; 2009 Tax Ct. Memo LEXIS 209; 98 T.C.M. (CCH) 57931;
September 14, 2009, Filed
P owned approximately 22,000 square feet (six stories) of unused development rights over a "certified historic structure" within the meaning of I.R.C. sec. 170(h)(4)(B). In 2003 P contributed to a charitable organization a conservation easement that restricted the development of 10,000 unspecified square feet of those unused development rights. P claimed on his tax return…
2Cases cited13 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- Hernandez v. CommissionerSupreme Court of the United States · 1989
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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