In this tax litigation, plaintiff-taxpayers donated a conservation easement to a land trust and claimed a charitable deduction for the asserted value of the easement. Judgment of the Tax Court holding that the easement did not qualify as a charitable contribution and that the taxpayers were not entitled to the deduction is affirmed, where an easement that grants a restriction for less than a perpetual term (such as the one at hand) may be a valid conveyance under state law but is still ineligible for a charitable deduction under federal law, as Internal Revenue Code section 170(h)(2)(C) requires that the gift of a conservation easement on a specific parcel of land be granted in perpetuity to qualify for a federal charitable deduction.