
Englewood Place LLC v. Commissioner T.C. Memo. 2020-105
On July 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Englewood Place LLC v. Commissioner (T.C. Memo. 2020-105). The primary issue before the court in Englewood Place LLC v. Commissioner was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of a conservation easement in full because the conservation purpose underlying the easements was not “protected in perpetuity” as required by IRC § 170(h)(5)(A), insofar as



