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GLASS v. C.I.R.

No. 06-1398.

471 F.3d 698 (2006)

Charles and Susan GLASS, Petitioners-Appellees, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

December 21, 2006.

Attorney(s) appearing for the Case

ARGUED: Bethany B. Hauser, United States Department of Justice, Washington, D.C., for Appellant. Charles F. Glass, Harbor Springs, Michigan, pro se. Stephen J. Small, Boston, Massachusetts, for Amicus Curiae. ON BRIEF: Bethany B. Hauser, Kenneth L. Green, United States Department of Justice, Washington, D.C., for Appellant. Charles F. Glass, Susan Glass, Harbor Springs, Michigan, pro se. Stephen J. Small, Boston, Massachusetts, for Amicus Curiae.

Before DAUGHTREY and GIBBONS, Circuit Judges; EDMUNDS, District Judge.

EDMUNDS, District Judge.

On 1992 and 1993 tax returns, Charles and Susan Glass ("Taxpayers") claimed charitable deductions for two conservation easements. The Commissioner of Internal Revenue (the "Commissioner") issued a notice of deficiency. Taxpayers filed a petition in the Tax Court challenging the Commissioner's decision. The Commissioner conceded that the 1992 and 1993 contributions met two of the three requirements for a "qualified conservation contribution...

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