Deduction denied for modifiable conservation easement

Deduction denied for modifiable conservation easement

A 22-acre conservation easement that could be modified by the donor for up to 5% of the area for up to five years is not a “qualified real property interest” and therefore its value is not deductible, the Tax Court has ruled.  It has upheld the IRS disallowance of a charitable contribution deduction claimed by a limited liability company.

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