In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more
In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
3/7/2024
/ Appraisal ,
Charitable Donations ,
Conservation Easements ,
Fair Market Value ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Court ,
Tax Deductions ,
Tax Fraud ,
Tax Liability ,
Tax Planning
Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more
12/21/2022
/ Administrative Procedure Act ,
Comment Period ,
Conservation Easements ,
Income Taxes ,
IRS ,
Proposed Regulation ,
Rulemaking Process ,
Tax Court ,
Tax Reform ,
Tax Shelters ,
Transaction Reporting
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
11/16/2022
/ Administrative Procedure Act ,
Charitable Deductions ,
Conservation Easements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Partnerships ,
Tax Avoidance ,
Tax Court ,
Tax Deductions ,
Tax Penalties ,
Tax Planning
As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more