IRS Defends Tide of Conservation Easement Summonses as Lawful

The IRS moved to dismiss a lawsuit alleging the agency had issued dozens of unlawful and purposeless summonses in its audit of a property holding company’s conservation easement donation.

Norcave Properties LLC sued the IRS last November in three separate actions, urging that the agency’s 37 summonses should be quashed because most of their subjects had minimal involvement in Norcave’s donation and subsequent charitable contribution tax deduction. The summonses therefore lacked legitimate purpose, and only served to place unnecessary burdens on Norcave and its business partners, its petitions said then.

Norcave had claimed a $108 million charitable contribution deduction on ...