IRS Wins on $17.5 Million Tennessee Land Donation Dispute

Nov. 2, 2020, 10:05 PM UTC

The U.S. Tax Court sided with the IRS in disallowing a $17.5 million deduction on a Tennessee conservation easement, ruling that the land wasn’t protected in perpetuity.

Glade Creek Partners LLC donated 1, 313 acres of land in Bledsoe County, Tenn. and claimed a $17.5 million charitable contribution deduction in their 2012 tax returns. The deal is what is known as a conservation easement, in which taxpayers donate land-use rights for the purpose of preservation. The donation can be tax-deductible if the requirements of tax code Section 170(h) are met.

The IRS challenged the easement ...

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