The tax matters partner of a partnership was not entitled to a charitable contribution deduction because the conservation purpose underlying the easement was not protected in perpetuity as required by Code Sec. 170(h)(5)(A).
See full opinion by clicking Belair Woods, LLC v Commissioner, TC Memo 2020-112 (July 22, 2020).
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal..