Charles F. and Susan G. Glass - Page 22

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          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            






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