On February 28, 2022, the Tax Court issued a Memorandum Opinion in the case of Corning Place Ohio LLC v. Commissioner (T.C. Memo. 2022-12). The primary issue presented in Corning Place Ohio LLC v. Commissioner was whether the taxpayer and the tax matters partner substantially complied with the reporting requirements necessary to substantiate a conservation easement deduction for the façade of a historic building. Background to Corning Place Ohio LLC v. Commissioner This case involves a charitable contribution deduction claimed by Corning Place Ohio, LLC (Corning Place), for a conservation easement. The IRS issued Corning Place a notice of final partnership administrative adjustment (FPAA) disallowing this deduction. Before the Court on the IRS’s motion for summary judgment were three issues: (1) whether the easement deed failed to protect the conservation purpose in perpetuity, in alleged violation of IRC § 170(h)(5)(A); (2) whether Corning Place's appraisal and baseline documentation failed to…