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Land Impvts. Total
Before Value $524,000 $387,300 $912,000
Less: After Value 157,000 387,300 545,000
Easement Value (rounded): $367,000 N/A $367,000
OPINION
I. Introduction
Petitioners assert that they made a bargain sale of the
easement to Howard County and that they are entitled to claim a
charitable contribution equal to the difference between the fair
market value of the easement and the amount realized from the
sale. Respondent contends that petitioners have failed to
demonstrate that the fair market value of the easement exceeded
the amount realized from the sale. There is no dispute regarding
petitioners' satisfaction of any other requirements set forth in
section 170 and the regulations thereunder, including whether the
contributed property (if any) constitutes a “qualified
conservation contribution” under section 170(h)(1). Therefore,
the only issues we must address are the fair market value of the
easement and the amount realized from the sale.
II. Principal Provisions of Law
Section 170(a)(1) provides the following general rule with
respect to charitable contributions:
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