IRS’s Denial of $20.67 Million Land Donation Deduction Gets Nod

The IRS properly disallowed a $20.67 million charitable contribution deduction claimed by a partnership in Georgia because the partnership failed to attach a qualified appraisal of the property to its tax return, the US Tax Court said Wednesday.

Oconee Landing Property LLC claimed the deduction on its 2015 partnership return for donating a conservation easement in Greene County, Ga., premised on its assertion that the donated tract of land, roughly 355 acres, was worth $59,718 per acre before the easement was granted. Oconee petitioned the Tax Court for review in 2019 after the IRS denied the deduction and determined a ...