Abstract
The US Court of Appeals for the Eleventh Circuit, by decision dated June 23, held that a charitable deduction for a gift of a conservation easement is not available because the conservation purpose was not protected in perpetuity by reason of a defective extinguishment provision in the easement deed and that an alternative provision in the deed was an unenforceable condition subsequent savings clause (TOT Property Holdings, LLC v. Commissioner). This appellate court affirmed the US Tax Court decision in the case (summarized in the March 2020 issue).
Published Version
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