IRS Hit With $148 Million Conservation Easement Deduction Suit

The IRS should allow a $148 million charitable contribution tax deduction claim for a partnership’s conservation easement donation, the donor told the US Tax Court.

Natural Rock LLC donated a conservation easement over its 226-acre property in Edmonson County, Ky., to the nonprofit corporation Barn Group Land Trust Inc. in order to claim a deduction for its alleged $148 million fair market value.

The partnership sued the IRS on July 9 for denying the deduction, accusing the agency of proffering an arbitrary and invalid tax adjustment.

The IRS asserted an imputed $54.9 million underpayment against Natural Rock, plus $21.9 million ...