IRS Wrongly Denied $78 Million Conservation Easement, Firm Says

The IRS acted wrongly when it disallowed a nearly $78 million conservation easement deduction on a piece of Louisiana land, its owner said.

Persimmon Gully Property LLC, an affiliate of Missouri-based CRA Investment, petitioned the US Tax Court to contest the IRS’ denial of a charitable conservation easement deduction for a 204-acre parcel of land it owns in southern Louisiana. It had donated an easement to Georgia nonprofit The Barn Group Properties LLC and claimed a $78.5 million easement on its 2019 tax return.

The IRS had denied the claimed easement and determined it under-paid its taxes by $29 million ...