The IRS doubled down on its litigation stance in safe harbor deed language for conservation easements released this month, following conflicting appeals courts’ decisions, tax practitioners say.
The agency on April 10 released Notice 2023-30, which laid out specific language to include in new or existing deeds that would protect landowners’ deductions, should the easement be extinguished or impacted by boundary line adjustments. But the language mirrors a controversial Treasury regulation regarding easement extinguishments that’s been the subject of several legal challenges.
A decision split between the 6th and 11th circuit courts of appeals over the Treasury regulation has ...
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