Belk v. Comr., T.C. Memo. 2013-154

(court denies reconsideration of its decision in 140 T.C. No. 1 (2013) in which the court held that petitioner was not entitled to charitable deduction for donation of conservation easement on 185 acres of golf course due to provision in grant allowing substitution of donated property; such power of substitution not consistent with Treas. Reg. Sec. 1.170A-14(b)(2) which requires that use restrictions of easement be perpetual).