- 22 -
market value of $241,800. Frame stated in the letter that he had
estimated that the fair market value of encumbered shoreline 2
was $483,600 before conservation easement 2 was imposed, that the
fair market value of encumbered shoreline 2 was $193,400 after
conservation easement 2 was imposed, and that conservation
easement 2 enhanced by $48,400 the fair market value of the
portion of the property that was not covered by conservation
easement 2. Frame concluded in the letter that these numbers
resulted in the claimed $241,800 fair market value for
conservation easement 2 ($483,600 - ($193,400 + $48,400) =
$241,800).
Petitioners claimed on their 1993 return that they had made
total charitable contributions of $266,602, consisting of a
$241,800 noncash contribution of conservation easement 2, cash
contributions of $11,414, and the $13,388 carryover from 1992.
Petitioners deducted on their 1993 return $128,473 of the total
claimed contributions and carried over the $138,129 balance to
1994. Petitioners later deducted $86,939 of the carryover for
1994 and the remainder for 1995.
VII. The Conservation Easements
Development of the lakefront immediately to the north and
south of the property is not limited by any restrictive easement
similar to the conservation easements. When petitioners
contributed the conservation easements to the trust, petitioners
Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 NextLast modified: May 25, 2011