Salt Point Timber v. Commissioner

U.S. Tax Court, 2017 TC Memo 245, December 11, 2017: Easement not deductible because holders not limited to “qualified organizations”.

Salt Point Timber granted the Lord Berkeley Conservation Trust a conservation easement for which Salt Point Timber received some payment but claimed a $2,130,000 deduction for the charitable contribution of the value of the easement in excess [...]

Mitchell v. Commissioner

US Court of Appeals, 10th Circuit, No. 13-9003, January 6, 2015: No deduction for conservation easement without mortgage subordination at time of grant.

This decision affirms the US Tax Court decision in Mitchell v. Commissioner, 138 T.C. 324 (2012) (Mitchell I) (of which the Tax Court rejected reconsideration in Mitchell II, T.C. Memo. 2013-204, August 29, 2013), [...]