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Browning v. Commissioner

109 T.C. 303 (1997)

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Browning v. Commissioner

United States Tax Court
109 T.C. 303 (1997)

CC

Facts

Charles and Patricia Browning (plaintiffs) engaged in litigation with the Commissioner of the Internal Revenue Service (IRS) (defendant) over the IRS’s claim that the Brownings failed to pay sufficient income tax from 1990 to 1993. The claim arose from a charitable contribution claimed by the Brownings on their federal tax returns after they voluntarily conveyed a restriction easement in perpetuity on their land to Howard County, Maryland, pursuant to the county’s Agricultural Land Preservation Program (Program). The county paid the Brownings $309,000 for the easement, which prohibited development of the land beyond agricultural uses. The Brownings and county officials acknowledged that $309,000 was less than the easement’s fair market value (FMV) and thus constituted a bargain sale, in which part of the conveyance was by sale and part was by gift. The Brownings claimed their gift to the county amounted to over $250,000, based on their experts’ testimony. The IRS countered that the FMV of the easement was simply the price paid by the county, such that there was no bargain sale, no gift, and no charitable contribution to be claimed. Alternatively, the IRS claimed that the FMV of the easement was far less than the Brownings claimed, and they still owed taxes.

Rule of Law

Issue

Holding and Reasoning (Halpern, J.)

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