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Charitable Contributions of Conservation Easements  


Author:  Staff Editors.


Source: Volume 20, Number 02, January/February 2021 , pp.9-9(1)




Family Foundation Advisor

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Abstract: 

Cases keep piling up considering whether a charitable contribution deduction is available for the donation of a conservation easement to a charitable organization. The result often depends on whether the perpetuity requirement in Section 170(h)(5)(A) (requiring that, for a contribution to be treated as “exclusively for conservation purposes,” the conservation purpose must be “protected in perpetuity”) has been satisfied.

Keywords: Perpetuity Requirement; Carter v. Commissioner; Hoffman Properties II, LP v. Commissioner; Rock Creek Property Holdings, LLC v. Commissioner

Affiliations:  1: Journal of Taxation of Investments.

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