Tennessee Partnership Challenges $22.9 Million Easement Denial

The IRS wrongly rejected a nearly $23 million deduction for a conservation easement on Tennessee property by failing to accurately assess the land, according to a petition to the US Tax Court.

French Broad River Reserve LLC donated roughly 285 acres in Cocke County, Tenn., to Foothills Land Conservancy and claimed a noncash charitable contribution deduction on its 2018 tax return, according to its Feb. 17 petition. But the IRS determined the easement was worth nothing because the partnership failed to provide qualified appraisals, fair market value documents, and other relevant records to support its asserted $22.9 million deduction. ...