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Income Tax Keyed to Graetz
Boltar, LLC v. Commissioner
Citation:
136 T.C. 326 (2011)Facts
In December 2003, Petitioner granted to a charitable land trust an easement on eight acres of its land, restricting any use of those eight acres which would interfere with its conservation value. On its 2003 tax return, Petitioner claimed a charitable contribution deduction of $3,245,000 related to the conservation easement. This number was based on a calculation of the difference between the “highest and best use” of the land, determined to be a series of condominium developments, and the value of the land if it remained undeveloped.
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