Partnerships Head to Court Over $200 Million in Easement Claims

Another set of partnerships have filed suit to dispute IRS denials of conservation easement tax deductions, as the US Tax Court’s long list of cases on the topic continues to grow.

A quartet of partnerships hailing from the southeastern US filed petitions in the US Tax Court disputing IRS disallowances of their claimed conservation easement tax deductions. The IRS denied each transaction was a donation for tax purposes. In total it disallowed over $200 million in tax deductions and imposed tens of millions of penalties for each partnership.

Sandwood Holdings LLC petitioned over a $58 million conservation easement on a ...