US Tax Court Easement, Micro-Captive Cases Continue to Balloon

The US Tax Court is dealing with over 1,000 conservation easement cases and 1,000 micro-captive insurance cases, respectively, the court’s chief judge said Thursday.

“Some of them are settling and some of them are not,” Chief Judge Kathleen Kerrigan said, adding that the court is trying to group some of the cases to manage the load. She was speaking at the UCLA Tax Controversy Conference in Los Angeles.

As of March, the court was seeing at least 750 easement cases.

The IRS is classifying some tax avoidance transactions as “listed transactions,” requiring certain uses to be reported to the ...