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LTC also helps the landowner find an appraiser to value the
contributed property by furnishing the landowner with a list of
appraisers, all of whom attended a seminar on the subject
sponsored by LTC. LTC also usually gives the landowner some
brochures explaining the mechanics of a conservation easement and
a guide detailing the tax ramifications of a conservation
easement and the contribution thereof. LTC does not value any
easement that it receives from a landowner, and LTC does not
acknowledge or accept any valuation of the easement. LTC usually
verifies its receipt of a contributed easement by signing Form
8283, Noncash Charitable Contributions.
LTC does not on an annual basis formally monitor each
conservation easement that it receives to ensure compliance but
occasionally monitors them informally. LTC maintains a file for
each of these easements.
OPINION
We decide whether petitioners’ contributions of the
conservation easements are qualified conservation contributions
under section 170(h)(1). Petitioners argue they are.13
According to petitioners, the conservation easements prohibit any
construction, development, or disturbance of the natural state of
13 While petitioners filed the lawsuit to reform the deeds
underlying the conservation easements, we decide this case on the
basis of the specific property that petitioners actually
contributed to the trust in 1992 and 1993.
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