IRS Hit by Tax Lawsuit Over $19 Million Easement Donation Claim

July 3, 2024, 8:38 PM UTC

The IRS should allow a $19.9 million charitable contribution tax deduction for a Georgia partnership’s conservation easement donation, the donor told the US Tax Court.

MR Minerals LLC accused the IRS of acting arbitrarily, in violation of the Administrative Procedure Act, when it determined the partnership’s multimillion-dollar easement conveyance couldn’t support its claimed tax benefit. MR Minerals donated a conservation easement over its 320-acre property in Twiggs County, Ga., to the nonprofit corporation, Southern Conservation Trust Inc., in order to claim a deduction for its alleged fair market value.

The IRS offered “no support” for its determination that MR Minerals’s ...

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