Charles F. and Susan G. Glass - Page 30

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               As to the first of the three requirements, an interest in              
          real property is a qualified real property interest if the                  
          interest is the donor’s entire interest in that real property               
          (other than a qualified mineral interest), a remainder interest,            
          or a restriction granted in perpetuity on the use which may be              
          made of the real property.  Sec. 170(h)(2).  In the case of the             
          latter, i.e., a restriction granted in perpetuity on the use                
          which may be made of the real property, the regulations                     
          interpreting that provision clarify that such a restriction must            
          be legally enforceable to limit any use of the real property that           
          is inconsistent with the conservation purpose of the                        
          contribution.  See sec. 1.170A-14(g)(1), Income Tax Regs.  These            
          regulations note that this requirement may be met by recording              
          the restriction in the land records of the jurisdiction in which            
          the real property is located.  Id.                                          
               As to the second of the three requirements, a contributee is           
          a qualified organization if it is described in section 170(h)(3).           
          The regulations interpreting this provision mandate that the                
          organization be committed to protecting the conservation purposes           
          of the contribution and have the resources necessary to enforce             
          the restrictions granted in perpetuity.  Sec. 1.170A-14(c)(1),              
          Income Tax Regs.                                                            
               As to the third of the three requirements, a contribution is           
          made exclusively for conservation purposes if it meets the tests            






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