MEMORANDUM OPINION
KROUPA, Judge:
Respondent determined a $124,662 deficiency in petitioners' Federal income tax for 2002 by denying a $390,629 charitable contribution pass-through deduction petitioners carried over from 2000 regarding conservation easements on real estate owned by the Goldsby-Matthews Trust (the trust). We are asked to decide as a threshold issue whether petitioners may deduct the charitable contribution. We conclude that they may not....
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