- 23 -                                         
          requirements.  We accordingly begin our discussion of the third             
          requirement by considering those two aspects.9                              
          b.  Satisfaction of the Third Requirement                                   
               In Glass v. Commissioner, 124 T.C. 258, 278-284 (2005),                
          which also involved the contribution of a conservation easement,            
          this Court considered the requirement that a contribution be made           
          exclusively for conservation purposes.  The discussion in that              
          case, however, was directed to whether the taxpayer satisfied the           
          natural habitat requirement.  That discussion, accordingly, did             
          not focus on the requirements we consider here.10  Accordingly,             
          we proceed to consider and analyze the two elements in dispute in           
          this case.                                                                  
                    (1)  Open Space Requirement                                       
               Petitioners allege that they satisfy the open space                    
          requirement of section 170(h).  Satisfaction of this requirement            
          requires both the preservation of open space and the inurement of           
          a significant public benefit.  Sec. 170(h)(4)(A)(iii).  The                 
               9Because we ultimately hold that petitioners have not                  
          satisfied the third requirement, there is no need to consider the           
          first requirement or the easement’s value.                                  
               10In addition, because we hold that petitioners do not                 
          satisfy either the open space or the historic preservation                  
          requirement, we need not consider whether the contribution was              
          “exclusively” for conservation purposes, as we did in Glass v.              
          Commissioner, 124 T.C. 258, 278-284 (2005).                                 
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