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MITCHELL v. C.I.R.

No. 13-9003.

775 F.3d 1243 (2015)

Ramona L. MITCHELL, Petitioner-Appellant, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

January 6, 2015.

Attorney(s) appearing for the Case

Larry D. Harvey , Englewood, CO, for Appellant.

Bethany B. Hauser , Tax Division, Department of Justice ( Francesca Ugolini , Tax Division, Department of Justice, and Tamara W. Ashford , Acting Assistant Attorney General, with her on the brief), Washington, D.C., for Appellee.

Before HOLMES, MATHESON, and McHUGH, Circuit Judges.

The Petitioner, Ramona L. Mitchell, appeals the decision of the United States Tax Court denying a charitable contribution deduction for a donation of a conservation easement on real property that was, at the time of the donation, subject to an unsubordinated mortgage. Specifically, she challenges the Tax Court's conclusion...

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