- 5 - The trust conveyed conservation easements on the Duck Lake property and the Riverbend/M’hoons Bend property to the Mississippi Land Trust in 2000. Respondent acknowledges that the Mississippi Land Trust is a qualified charitable organization under section 501(c)(3). The trust obtained appraisals of the Duck Lake property and the Riverbend/M’hoons Bend property both before and after the conservation easements that indicated the value of the conservation easements was $5,640,000. Tax Reporting of the Conservation Easement Donations The trust reported its donation of the conservation easements on its Form 1041, U.S. Income Tax Return for Estates and Trusts, for 2000 and reported that the charitable contribution was allocated to the sole income beneficiary, petitioner. The Schedule K-1, Beneficiary’s Share of Income, Deductions, Credits, etc., attached to the trust’s Form 1041 reported the entire $5,640,000 claimed charitable contribution deduction as passing through to petitioner as the sole income beneficiary. Petitioners deducted a portion of the trust’s charitable contribution on their Federal income tax return for 2000 and carried over the balance subject to the adjusted gross income limitations of section 170(b). Petitioners carried over and deducted portions of the trust’s charitable contribution on their Federal income tax returns for 2001, 2002, 2003, and 2004.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011