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COSTELLO v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 24995-12.

T.C. Memo. 2015-87

DAVID C. COSTELLO AND BARBARA A. COSTELLO, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 6, 2015.

Attorney(s) appearing for the Case

Glen Michael Anderson and Michael G. Campbell , for petitioners.

Warren P. Simonsen and Christopher R. Moran , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

Petitioners own a large farm in Howard County, Maryland. In 2006 they granted in favor of the county a land preservation easement on this property. By granting this easement, petitioners became entitled, as part of a "density exchange," to sell to a developer the development rights...

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