Conservation Easement's Valuation Held to Support Promotion, Unreasonable

Abstract

The US Tax Court, by decision dated November 2, held that a contribution of a conservation easement on undeveloped real estate did not give rise to the claimed charitable deduction ($17.5 million) inasmuch as it failed the in‐perpetuity requirement because of a defective judicial‐extinguishment clause, and that the 20 percent accuracy‐related penalty for a substantial valuation misstatement was properly imposed (Glade Creek Partners, LLC v. Commissioner).