Is a personal trust entitled to a full fair market value deduction for a gift of real estate just like an individual or corporate taxpayer? No, says the Tenth Circuit Court of Appeals in what appears to be a case of first impression in the courts. It has reversed a District Court opinion and held that the deduction is limited to the adjusted tax basis of the property under the special provisions of section 642(a)(1) of the Tax Code. David M. Green and Barbara A. Green created a “Dynasty Trust” in 1993 to provide for their family and certain charitable contributions. The Trust owned a 99 percent ownership interest in Hob-Lob Limited Partnership, which owns most of the “Hobby Lobby” retail...