On February 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Carter v. Commissioner (T.C. Memo. 2020-20). The issues presented in Carter v. Commissioner were whether the restrictions contained in a conservation easement violated IRC § 170(h) and whether the IRS had satisfied the prior written supervisory approval requirement of IRC § 6751(b)(1). Background to Carter v. Commissioner The petitioners, through their partnership, conveyed an easement to NALT, a “qualified organization”