PLR 199952037
Author
About This Legal Opinion
Taxpayer and a business partner jointly own multiple parcels of real estate, some of which have been commercially developed and some of which are undeveloped farmlands. In Year, Taxpayer acquired approximately 115 acres of farmland in Township, County, State. Taxpayer and the business partner own the property as tenants in common. Taxpayer intends to partition the 115 acres into two parcels: a 110-acre parcel (the "Property") and a five-acre parcel (the "Residential Parcel"). Currently, Taxpayer leases the Property to a farmer who uses it to produce various crops. The Residential Parcel is improved with a house and a barn and currently is leased to a party who is unrelated to either the farmer or Taxpayer. After the partition, Taxpayer intends to grant a conservation easement on the Property and to sell the Residential Parcel. Taxpayer represents that there are no plans to develop further the Residential Parcel.
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