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MITCHELL v. COMMISSIONER

Docket No. 10891-10.

138 T.C. 324 (2012)

RAMONA L. MITCHELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 3, 2012.

Attorney(s) appearing for the Case

Larry D. Harvey , for petitioner.

Miles B. Fuller , Steven I. Josephy , and Joseph A. Peters , for respondent.

HAINES, Judge:

Respondent determined a deficiency of $142,600 in petitioner's Federal income tax and an accuracy-related penalty under section 6662(a)1 and (d) of $28,520 for 2003.2 The issues for decision after concessions are: (1) whether petitioner is entitled to a charitable contribution deduction with respect to the conservation easement she granted to Montezuma Land Conservancy (Conservancy); ...

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