§2124

1520, 1916. Congress then recycled nearly identical language, i.e., the “certified historic structure” definition and certification framework, four years later when enacting what became section 170(h)(4) as part of the Tax Treatment Extension Act of 1980, Pub. L. No. 96-541, § 6(b), 94 Stat. 3204, 3207. B. Regulatory Framework The

1520, 1919, with Tax Treatment Extension Act of 1980, Pub. L. No. 96-541, § 6, 94 Stat. 3204, 3206. The significance of NYLC’s comment is underscored by the backdrop of Congress’s considerable policy shift over such a short period of time. 21 In Oakbrook I the opinion of the Court reasoned that Treasury “clearly considered” com

eduction only in situations where the conservation purposes ofprotecting or preserving the property will in practice be carried out. Thus, it is intended that a contribution ofa conservation easement "The Tax Reform Act of 1976, Pub. L. No. 94-455, sec. 2124(e), 90 Stat. at 1919, authorized a deduction for the donation ofan "easement with respect to real property * * * exclusively for conservation purposes". See Glass v. Commissioner, 124 T.C. 258, 277-280 (2005) (examining the legislative histo

gross is to be considered a gift ofan undivided interest in property where the easement is in perpetuity." Congress made explicitan exception for (i.e., permitted a deduction for) certain easements in the Tax Reform Act of 1976, Pub. L. No. 94-455, sec. 2124(e), 90 Stat. at 1919, which amended section 170(f)(3)(B) to provide in clause (iii) that a donor may claim a deduction for the contribution ofan "easement with respect to real property ofnot less than 30 years' duration granted to * * * [a c

2124(e), 90 Stat. 1919, authorized a deduction for the donation of an "easement with respect to real property of not less than 30 years' duration" granted to a governmental unit or qualifying charitable organization made "exclusively for conservation purposes". See Glass v. Commissioner, 124 T.C. 258, 277-280 (2005) (examining the legislative

Section 2124 allows a deduction for expenses to produce or collect income or to manage, etc., property held for the production of income. Section 212 is coextensive in most respects with section 162(a), and taxpayers may not deduct expenses under section 212 that could not be deducted under section 162(a) were the expenses connected to a trade or b