James D. and Beverly H. Turner - Page 3

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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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