Abstract
A company executed in favor of New York's Trust for Architectural Easements a historic preservation deed of easement, claiming a charitable contribution deduction of $64.5 million. The US Tax Court, on December 22, ruled that this deduction is unavailable because the Trust did not provide the donor with the requisite substantiation letter (15 West 17th Street, LLC v. Commissioner). The court also rejected the donor's attempt to salvage the deduction by reason of the alternative donor‐reporting option.
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