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second in 1993. Ps claimed on their 1992 and 1993
Federal income tax returns that the contributions were
qualified conservation contributions under sec.
170(h)(1), I.R.C. R concedes that the contributions
meet two of the three requirements for such a
characterization; i.e., the portions of the bluff
covered by the conservation easements are each a
“qualified real property interest” and L is a
“qualified organization”. R asserts that the
contributions fail the third requirement, that they be
“exclusively for conservation purposes”.
Held: Each of the contributions is a qualified
conservation contribution under sec. 170(h)(1), I.R.C.,
in that (1) the conservation easements protect a
relatively natural habitat of plants or wildlife as
required by sec. 170(h)(4)(A)(ii), I.R.C., and (2) L
(or any subsequent holder of the conservation
easements) holds (or will hold) the conservation
easements exclusively for conservation purposes as
required by sec. 170(h)(5), I.R.C.
Charles F. Glass and Susan G. Glass, pro sese.1
Alexandra E. Nicholaides, for respondent.
LARO, Judge: Petitioners petitioned the Court to
redetermine deficiencies of $26,539, $40,175, $26,193, and
$22,771 in their Federal income taxes for 1992, 1993, 1994, and
1995, respectively. We decide whether petitioners’ respective
contributions in 1992 and 1993 of two conservation easements
(collectively, conservation easements; separately, conservation
1 William B. Acker petitioned the Court on behalf of
petitioners and continued to represent them until he withdrew on
Mar. 25, 2002.
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