ROTH v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 5544-12.

T.C. Memo. 2017-248

JOHN L. ROTH AND DEANNE M. ROTH, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed December 28, 2017.


Attorney(s) appearing for the Case

Justin D. Cumming and James R. Walker , for petitioners.

Sara J. Barkley and Miles B. Fuller , for respondent.


MEMORANDUM OPINION

In 2007 petitioners granted a conservation easement to a qualified charitable organization. They claimed a charitable contribution deduction for tax year 2007 and a carryover deduction for tax year 2008, together totaling $970,000. Respondent disallowed the deductions and determined Federal income tax...

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