Date of Publication: 08/23/2013
Response regarding the valuation of perpetual conservation restrictions, or conservation easements. Specifically focuses on the application of the “Contiguous Parcel Rule” and the “Enhancement Rule” found in § 1.170A-14(h)(3)(i) of the Income Tax Regulations.
Memo available at:
www.irs.gov/pub/irs-wd/1334039.pdf