A conservation easement over land including a private golf course qualifies for a charitable contribution, the 11 th Circuit Court of Appeals has held. It has reversed and vacated a Tax Court decision denying the deduction. An easement qualifies for a deduction, the Court said, if it was made for “the protection of a relatively natural habitat of fish, wildlife, or plants, or similar ecosystem,” or was made for “the preservation of open space ... for the scenic enjoyment of the general public.” After becoming aware that the Tax Court had allowed an easement over a golf course in 2009, Champions Retreat Golf Founders, which had purchased 463 acres along the Savannah River north of Augusta,...