Cohan v. Comr., T.C. Memo. 2012-8

(family partnership received interests in various properties as consideration for transfer (bargain sale) of right-of-first refusal on encumbered farmland to charity (conservation organization); court redetermined fair market value such that each tract included value of beach rights; valuation approach of IRS expert generally upheld except that expert should have accounted for public access over one tract that would decrease value; gain attributable to beach rights not taxable to partners due to lack of capital interest in petitioner; petitioner's charitable deduction denied due to deficiencies of acknowledgement letter from charity; letter did not disclose certain items that donor received in return for gift and petitioner's reliance on letter not reasonable; accuracy-related penalty upheld).