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Vacation Home With Conservation Easement Qualifies for QPRT
A personal residence can be exempt from the valuation rules of §2702. The term "personal residence" has been found to include a range of different properties which can then be transferred to a qualified personal residence trust (QPRT). The IRS recently ruled that a vacation home qualified for QPRT treatment even though it had two separate lots, vacation amenities such as a jacuzzi, one-bedroom cabin, and a tennis court. The improvements to the land did not exceed what was reasonably appropriate for residential uses. There was also sufficient land to warrant the use of a conservation easement. Though considerable in size, the amount of land was comparable to other homes in the vicinity.
Source: Letter Ruling 200109017
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