Thomas B. Goldsby, Jr. and Sandra C. Goldsby - Page 5

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               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.            







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