The Tax Court has denied charitable contribution deductions for conservation easements on property held for a year and a day when the deeds provided that the easements could be extinguished in whole or in part “by mutual written agreement of both parties.” The Court did not question whether the easement met conservation requirements or that the recipient was a qualified conservation entity, but said the Tax Code required that the conservation purposes had to be protected “in perpetuity.” It recognized that courts have previously applied a “so-remote-as-to-be-negligible standard” to permit deductions for easements that could be lost under extremely remote situations. But that standard could...