Company Can’t Block IRS in $180 Million Easement Deduction Spat

A land company can’t challenge an IRS notice over a $180 million tax deduction sought on donated land because its lawsuit is blocked by the Anti-Injunction Act, the Eleventh Circuit said.

Hancock County Land Acquisitions LLC claimed the deduction on Mississippi land it donated as a conservation easement, which is property donated to be “protected in perpetuity” under tax code Section 170(h). The IRS launched an investigation into the company’s tax return, issuing a Final Partnership Administrative Adjustment (FPAA) to Hancock and its tax matters partner in 2020.

Hancock sued, claiming that the adjustment would allow ...