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ZARLENGO v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 3701-10, 26747-10.

T.C. Memo. 2014-161

MARCO ZARLENGO AND LINDA McMAHON-ZARLENGO, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. MERILYN H. SANDIN-ZARLENGO, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed August 11, 2014.

Attorney(s) appearing for the Case

Frank Agostino , Jairo G. Cano , and Jeremy M. Klausner , for petitioners.

Marc L. Caine and Eliezer Klein , for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

VASQUEZ, Judge.

The issues for decision in these consolidated cases are (1) whether petitioners are entitled to noncash charitable contribution deductions under section 170 with respect to the donation of a facade conservation easement (conservation easement) to the National Architectural Trust (Trust) and (2) whether petitioners are liable for accuracy-related penalties under section 6662(h) or (a).

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