Land Deal Deed Sinks $7 Million Tax Break, Appeals Court Says

A company fighting for a nearly $7 million tax deduction doesn’t qualify for the perk because language in the deed meant the related land donation wasn’t protected in perpetuity, the Eleventh Circuit said Wednesday.

The ruling is a setback for TOT Property Holdings LLC, which challenged the IRS’s denial of a $6.9 million deduction it claimed on several hundred acres of Tennessee land donated in a conservation easement. The case is one of many involving the transactions, in which individuals can qualify for a charitable-giving tax deduction if the donation meets certain requirements laid out in tax code Section ...