CHAPTER SEVENUnique Charitable Contribution Laws

§ 7.6 EASEMENTS AND OTHER CONSERVATION PROPERTY

(c) Conservation Purpose

p. 281, note 205. Insert following existing text:

That rule notwithstanding, the charitable deduction is not jeopardized by reason of changes in the property due to upkeep or installation of one or more Americans with Disabilities Act–required accessibility ramps (Chief Couns. Adv. Mem. 2021-001).

(d) Requirement of Exclusivity

p. 284, second paragraph, first line. Insert, upheld by two courts of appeals, following Court.

p. 284, note 225. Delete text and insert:

PBBM-Rose Hill, Ltd. v. Commissioner, 900 F.3d 193 (5th Cir. 2018); TOT Property Holdings, LLC v. Commissioner, ___ F.3d ____ (11th Cir. 2021); Carroll v. Commissioner, 146 T.C. 196 (2016); Coal Property Holdings, LLC v. Commissioner, 153 T.C. 126 (2019); Railroad Holdings, LLC v. Commissioner, 119 T.C.M. (CCH) 1136 (2020); Oakhill Woods, LLC v. Commissioner, 119 T.C.M. (CCH) 1144 (2020); Oakbrook Land Holdings, LLC v. Commissioner, 119 T.C. 1351 (2020); Woodland Property Holdings, LLC v. Commissioner, 119 T.C.M. (CCH) 1361 (2020); ...

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