GOLDSBY v. COMMISSIONER

Docket No. 8232-05.

92 T.C.M. 529 (2006)

T.C. Memo. 2006-274

Thomas B. Goldsby, Jr. and Sandra C. Goldsby, v. Commissioner.

United States Tax Court.

December 27, 2006.


Attorney(s) appearing for the Case

Scott F. May, for petitioners.

Edsel Ford Holman, Jr., for respondent.


MEMORANDUM OPINION

KROUPA, Judge:

Respondent determined a $124,662 deficiency in petitioners' Federal income tax for 2002 by denying a $390,629 charitable contribution pass-through deduction petitioners carried over from 2000 regarding conservation easements on real estate owned by the Goldsby-Matthews Trust (the trust). We are asked to decide as a threshold issue whether petitioners may deduct the charitable contribution. We conclude that they may not....

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