§1702

The Eleventh Circuit concluded that Champions Retreat Golf Founders, LLC (Champions Retreat), is entitled to a charitable contribution deduction under section 1702 for the donation of a conservation easement in 2010.

The partnerships that donated the conservation easements claimed aggregate charitable contribution deductions under section 1702 in excess of $62 million.

terpleading a third party "forces the claimants to contest what essentially is a controversy between them without embroiling the stakeholder in the litigation over the merits of the respective claims." 7 Wright et al., Federal Practice and Procedure sec. 1702, at 534 (3d ed. 2001). Petitioner asserts that The case at bar is the exact type of case in which this Court should exercise its discretion to interplead the Government of the * * * [Virgin Islands] under Rule 22(a) (1). That is because Res

erpleading a third party "forces the claimants to contest what essentially is a controversy between them without embroiling the stakeholder in the litigation over the merits of the respective claims.” 7 Wright et al., Federal Practice and Procedure, sec. 1702, at 534 (3d ed. 2001). Petitioner asserts that The case at bar is the exact type of case in which this Court should exercise its discretion to interplead the Government of the * * * [Virgin Islands] under Rule 22(a)(1). That is because Resp

6662 1993 $44,235 $8,847 1994 13,133 2,627 - 2 - After concessions,1 the issue for decision is whether petitioners are entitled to charitable contribution deductions under section 1702 for 1993 and 1994 in the amounts of $126,605 and $50,513, respectively, for the donation of newspapers made in 1991 to the San Francisco Academy of Comic Art.