An oral subordination of existing mortgage liens is not effective under Missouri law and the Tax Court has denied a $16.4 million charitable contribution deduction for a gift of a conservation easement where the subordination was not filed of record for nearly four months after the grant of the easement. RP Golf, LLC claimed the deduction for the grant of an easement by its single-member limited liability company over 277 acres of golf course land. The deed was recorded on December 29, 2003. The tracts were subject to two mortgages. The donor claimed that it had obtained oral commitments from the lenders that they would not enforce the liens, but the written subordination agreements were...