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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