IRS Wins on $36 Million of Conservation Easement Disputes

The Tax Court has sided with the IRS in a trio of conservation easement cases, allowing the agency to disallow $36 million in deductions due to the properties not being protected in perpetuity.

In Tennessee, Plateau Holdings, LLC sought a $25.5 million deduction for two properties in the south-central area of the state, totaling 2,444 acres. In Georgia, Lumpkin One Five Six, LLC sought a $2.4 million deduction on a 156-acre tract in Lumpkin County, and Lumpkin HC (Hurricane Creek Partners), filed an $8.2 million deduction on 522 acres. ...