The Tax Court, in Ten Twenty Six Investors, v. Commissioner, T.C. Memo. 2017-115, held that a partnership was not entitled to a charitable contribution deduction for a conservation easement donation it made. The Court concluded that the perpetuity requirements of Code Sections 170(h)(2)(C) and (5)(A) were not satisfied because the deed was not recorded by the donee organization until two years after the donation.
See Ten Twenty Six Investors, v. Commissioner, T.C. Memo. 2017-115 by clicking here.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.