The Tax Court has denied charitable contribution deductions for two conservation easements that it concluded did not protect property from development “in perpetuity” and significantly reduced the claimed deduction for a third easement that it said did qualify. In a lengthy reviewed opinion spelling out much of the judicial history surrounding conservation easements, the Court held that carve-outs permitting construction within the easement area in unspecified areas to be agreed upon later between the landowner and the easement holder disqualified the two easements for deductions. The Pine Mountain Reserve acquired more than 6200 acres of land in Shelby County, AL, beginning in 2004. In...