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          organization”; and (3) the contribution is “exclusively for                 
          conservation purposes.”  Sec. 170(h)(1); see also sec. 1.170A-              
          14(a), Income Tax Regs.  To be a qualified conservation                     
          contribution, all three requirements must be met.                           
               A “qualified real property interest” must consist of the               
          donor’s entire interest in real property (other than a qualified            
          mineral interest) or consist of a remainder interest, or of a               
          restriction granted in perpetuity concerning way(s) the real                
          property may be used.  Sec. 170(h)(2).  A restriction granted in            
          perpetuity on the use of the property must be based upon legally            
          enforceable restrictions (such as by recording the deed) that               
          will prevent uses of the retained interest in the property that             
          are inconsistent with the conservation purpose of the                       
          contribution.  See sec. 1.170A-14(g)(1), Income Tax Regs.                   
               A qualified organization is defined in section 170(h)(3) and           
          a contribution is made “exclusively for conservation purposes” if           
          it meets the tests of section 170(h)(4) and (5).  This                      
          requirement has two parts.  First, a contribution is for a                  
          conservation purpose if it:  (1) Preserves land for the general             
          public’s outdoor recreation or education; (2) protects a                    
          relatively natural habitat of fish, wildlife, or plants, or                 
          similar ecosystem (the natural habitat requirement); (3)                    
          preserves open space either for the scenic enjoyment of the                 
          general public or pursuant to a Federal, State, or local                    
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