Taxpayers denied $504,000 deduction on conservation easement

The Tax Court has agreed with the IRS and denied a charitable contribution deduction of $504,000 to taxpayers who donated a conservation easement to a qualified conservation organization but did not simultaneously obtain a subordination of the purchase money mortgage on the property.  The Court said the taxpayers were not entitled to invoke the “so-remote-as-to-be-negligible” standard in determining whether they could claim the deduction.