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SCHEIDELMAN v. C.I.R.

Docket Nos. 10-3587-ag(L), 10-5316-ag(XAP).

682 F.3d 189 (2012)

Huda T. SCHEIDELMAN, Petitioner-Appellant-Cross Appellee, v. COMMISSIONER of INTERNAL REVENUE, Respondent-Appellee-Cross Appellant.

United States Court of Appeals, Second Circuit.

Decided: June 15, 2012.

Attorney(s) appearing for the Case

Frank Agostino (Eduardo S. Chung, on the brief), Agostino & Associates, P.C., Hackensack, N.J., for Petitioner-Appellant-Cross Appellee.

Patrick J. Urda (Kenneth L. Greene, on the briefs), for Gilbert Rothenberg, Acting Deputy Assistant Attorney General, U.S. Department of Justice, Washington, D.C., for Respondent-Appellee-Cross Appellant.

Before: JACOBS, Chief Judge, LEVAL and LIVINGSTON, Circuit Judges.

DENNIS JACOBS, Chief Judge:

Taxpayer Huda Scheidelman appeals a decision of the Tax Court disallowing her deduction for the value of a "facade conservation easement" that she donated to the National Architectural Trust (the "Trust"). The Tax Court ruled that the appraisal she obtained insufficiently explained the method and basis of valuation, and thereby failed to comply with the Treasury Regulation defining a qualified appraisal. See Treas. Reg. § 1...

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