LTR 8449025

A buyer under contract to buy land proposes to donate a conservation easement.

Letter in response to request for a ruling that the proposed perpetual conservation easement and a fee simple interest in the proposed replacement real property qualify as like-kind property under section 1031 of the Internal Revenue Code.

This is in response to a letter requesting rulings concerning the application of section 170 and 2522 of the Internal Revenue Code to the proposed grant of a conservation easement in real property.

This is in reply to a request for a ruling that a proposed contribution will be a qualified conservation contribution under section 170(h) of the Internal Revenue Code.

Reply to ruling request submitted on behalf of certain taxpayers as donors who propose to donate a conservation on Y to Z.

Response to letter requesting ruling that a proposed contribution of a conservation easement will be deductible as a qualified conservation contribution under section 170(h) of the Internal Revenue Code.

This is in reply to a letter requesting a ruling that the proposed conveyance of an easement to X is a deductible, charitable contribution under section 170 of the Internal Revenue Code.

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Reply to a request for ruling that a proposed contribution of an open space easement will be a qualified conservation contribution under section 170(h) of the Internal Revenue Code.

This responds to a request as to whether a proposed contribution by taxpayers will be a "qualified conservation contribution" within the meaning of section 170(h) of the Internal Revenue Code.