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Physicians and engineers are in general a lot smarter than accountants.  That's why some of them get into tax trouble .  Those are the ones who add ruffles and flourishes rather than doing things like everybody else does. They don't realize you best have a tax attorney involved if you are going to be fancy. That is what I see as the lesson in the Tax Court decision in the case of Douglas G. Carroll III.  The issue was a conversation easement.
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