- Ag Docket
(petitioner donated qualified conservation easement to National Architectural Trust on petitioner's townhouse (façade easement on historic property); IRS challenged appraisal of property as not being a "qualified appraisal" because it did not contain state method of valuation (even though petitioner's appraiser testified that he used the "before and after" approach; IRS also argued that Pension Protection Act expanded requirements for qualified appraisal by requiring that appraisal follow "generally accepted appraisal standards"; IRS claimed easement had no value insomuch as it mirrored restrictions in local law; court did not accept IRS' argument and noted that an easement restriction does reduce value of the restricted property; court determined two percent reduction in value due to easement restriction which resulted in charitable deduction of $104,000 rather than $605,000 that petitioner claimed; petitioner liable for I.R.C. Sec. 6662 penalty).
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