Charles H. Browning, Jr., and Patricia L. Browning - Page 14

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               There shall be allowed as a deduction any charitable                   
               contribution (as defined in subsection (c)) payment of                 
               which is made within the taxable year.  A charitable                   
               contribution shall be allowable as a deduction only if                 
               verified under regulations prescribed by the Secretary.                
               Section 1.170A-1(c)(1), Income Tax Regs., provides in                  
          pertinent part:  “If a charitable contribution is made in                   
          property other than money, the amount of the contribution is the            
          fair market value of the property at the time of the                        
          contribution”.  Fair market value, as defined by the regulations,           
          “is the price at which the property would change hands between a            
          willing buyer and a willing seller, neither being under any                 
          compulsion to buy or sell and both having reasonable knowledge of           
          relevant facts.”  Sec. 1.170A-1(c)(2), Income Tax Regs.                     
               Section 1.170A-7(c), Income Tax Regs., provides that, except           
          as provided in section 1.170A-14, Income Tax Regs., the amount of           
          the deduction under section 170 in the case of a partial interest           
          in property is the fair market value of the partial interest at             
          the time of the contribution.                                               
               Section 1.170A-14(h)(3)(i), Income Tax Regs., in part,                 
          provides as follows:                                                        
               The value of the contribution under section 170 in the                 
               case of a charitable contribution of a perpetual                       
               conservation restriction is the fair market value of                   
               the perpetual conservation restriction at the time of                  
               the contribution.  See �1.170A-7(c).  If there is a                    
               substantial record of sales of easements comparable to                 
               the donated easement (such as purchases pursuant to a                  

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