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BELK v. COMMISSIONER

Docket No. 5437-10.

140 T.C. 1 (2013)

B.V. BELK, JR., AND HARRIET C. BELK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 28, 2013.

Attorney(s) appearing for the Case

David M. Wooldridge , Ronald A. Levitt , and Gregory P. Rhodes , for petitioners.

Scott L. Little , for respondent.

VASQUEZ, Judge:

Respondent determined deficiencies of $806,375, $784,678, and $491,239 in petitioners' Federal income tax for 2004, 2005, and 2006, respectively. The issues for decision after partial settlement1 are: (1) whether petitioners are entitled to a charitable contribution deduction with respect to the conservation easement they granted to Smoky Mountain National Land Trust (SMNLT...

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