Abstract
A real estate developer obtained approval for an affordable housing project. On two occasions during the process, he contributed acreage to the town involved, claiming a charitable contribution deduction of $1.5 million on one occasion and $2.5 million on the other. The IRS disallowed carryover deductions on the grounds that the properties were transferred without charitable intent and failure to comply with the appraisal requirements. The donors prevailed in the US Tax Court on all points, by decision dated August 17, including valuation and avoidance of accuracy‐related penalties (Emanouil v. Commissioner).
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