The Tax Court has denied a charitable contribution deduction for the gift of a façade easement on property subject to a prior mortgage. The Court said that the easement might not be enforceable in perpetuity. Taxpayers granted an easement to the National Architectural Trust restricting the use of a residential property located in an historic preservation district in Boston. The property was subject to a prior mortgage. They claimed a charitable contribution deduction totaling about $220,000 over two years. In order to claim a charitable contribution deduction for a conservation easement, the gift must create an immediate property right in a qualified conservation organization with a fair...