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TURNER v. COMMISSIONER

Docket No. 5165-04.

126 T.C. 299 (2006)

126 T.C. No. 16

JAMES D. AND BEVERLY H. TURNER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 16, 2006.

Attorney(s) appearing for the Case

J. Carlton Howard, Jr., for petitioners.

John M. Altman and Linda R. Averbeck, for respondent.

GERBER, Chief Judge:

Respondent determined a $178,168 income tax deficiency and a $56,537 accuracy-related penalty under section 66621 for petitioners' 1999 taxable year. After concessions,2 the issues remaining for our consideration are: (1) Whether petitioners made a contribution of a qualified conservation easement under section 170(h)(1); (2) if qualified...

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