The Tax Court has upheld an IRS denial of a charitable contribution deduction for a developer’s grant of a conservation easement on 125 acres it planned for a public park adjacent to its planned unit development. The developer had claimed a deduction of $1,798,000 for the easement. Wendell Falls Development, LLC, acquired about 1280 acres of property outside the town of Wendell in Wake County, NC between 2004 and 2007. It sought to sell about 125 acres to the County and wanted to place the easement on the land so that its park use would be retained indefinitely. Its approved development plan called for a park on the 125 acres. The developer and the County agreed that placing the easement on...