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. Balsam Mountain Investments gave the easement on property in North Carolina to the North American Land Trust. The easement restricted “in perpetuity” any development within the “Conservation Area” covered by the easement. But the document allowed the LLC to make “minor alterations to the boundary of the Conservation Area.” It allowed the donor to substitute...