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(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.
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