Five law professors urged the U.S. Court of Appeals for the Eleventh Circuit to side with the IRS by disallowing $97.4 million in purported charitable deductions tied to a land conservation agreement.
The case raises questions about whether such deductions should be allowed when the agreement permits homes to be built on the plot of land or allows for modifications agreed to by the landowner and the donation holder. The case centers on a conservation easement, in which an individual can claim a charitable deduction under tax code Section 170(h) for donating the use of land or property ...