Appeals Court Affirms Tax Court’s $37 Million Easement Reduction

The US Tax Court properly cut down most of the $37 million in charitable contributions deductions taken for conservation easements claimed by two partnerships, the US Court of Appeals for the Eleventh Circuit held Wednesday.

Finding no error in the Tax Court’s valuation, Jackson Crossroads, LLC, and Long Branch Investments, LLC overstated the value of their $23.1 million and $13.8 million conservation easement deductions, and remain on the hook for 40% gross valuation misstatement penalties, the court said in a per curium opinion.

A conservation easement allows a property owner to donate the future development potential for a piece ...