Trout Ranch LLC, et al. v. Commissioner, T.C. Memo. 2010-283

(petitioner, an LLC taxed as a partnership, granted a conservation easement; IRS reduced charitable contribution from approximately $2.2 million to under $500,000 and then to $0; land at issue acquired with intent to subdivide and develop property along river; case involves battle over valuation approaches; court holds that value of contributed easement is $560,000 with contribution limit of 30% of contribution base; charitable contribution is a partnership item as the contribution was made by the partnership). 

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