- 3 - (1) Whether petitioners made a contribution of a qualified conservation easement under section 170(h)(1); (2) if qualified, we must decide the value of the easement; and (3) in the absence of a qualified contribution or, alternatively if the easement’s value was substantially overstated, whether petitioners are liable for the accuracy-related penalty under section 6662. FINDINGS OF FACT3 General Background At the time their petition was filed, petitioners resided in Alexandria, Virginia. Petitioner4 is an attorney whose practice is concentrated on real estate transactions in the vicinity of Alexandria, Virginia. Part of petitioner’s business activity was the conduct of real estate closings through a title insurance company he owned. Petitioner was also an investor in real property. At all relevant times, he was a 60-percent member and general manager of FAC Co., L.C. (FAC), a limited liability company formed for the purpose of acquiring, rezoning, and developing real property. During 1997 and 1998, petitioner, individually or through FAC, embarked on a plan to acquire several contiguous parcels of land located in Woodlawn Heights, 3The parties’ stipulation of fact is incorporated herein by this reference. 4Petitioners are husband and wife and they filed a joint return for the year in issue. References to petitioner alone are to petitioner James D. Turner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011