Facts

Michael Mountanos owned the Blue Lakes Ranch. In 2005, he conveyed a conservation easement on the ranch to the Golden State Land Conservancy. He later filed an individual federal income tax return, claiming a $4,691,500 charitable contribution deduction based on that easement. He then filed returns claiming carryover deductions for the following three years.

The Commissioner of Internal Revenue later disallowed those deductions, and issued a deficiency notice against Mountanos. Mountanos then filed a petition against the Commissioner.

PLAINTIFF'S CONTENTIONS:
Mountanos argued that he had properly claimed carrying charitable contribution deductions in his tax returns, and that the Commissioner was incorrect in issuing the deficiency notice against him.

DEFENDANT'S CONTENTIONS:
The Commissioner challenged the carryover deductions on multiple grounds, arguing that the conservation easement did not entitle him to the deductions he was claiming.

Result

The tax court ruled in favor of the Commissioner, concluding that Mountanos was not entitled to the carryover deductions he had claimed. It also denied Mountanos' later motions to consider alternative grounds for the deductions.