Minnick, et al. v. Comr., T.C. Memo 2012-345

(petitioner, former Democratic member of U.S. House and lawyer that practiced tax law, donated permanent conservation easement on 80 percent of 74-acre parcel to qualified land trust; land subject to mortgage at time of donation and mortgage not subordinated until two years after petitioner received statutory notice of deficiency from IRS; petitioner argued that state (ID) Uniform Conservation Easement Act protected charitable use, but court noted Act would have only protected whatever interest remained after lender satisfied; no partial subordination involved; negligence penalty imposed).