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
On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more
9/27/2023
/ Acquittals ,
Charitable Donations ,
Conservation Easements ,
Criminal Convictions ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fair Market Value ,
Investment ,
IRS ,
Jury Verdicts ,
Real Estate Market ,
Tax Avoidance ,
Tax Deductions ,
Tax Liability ,
Tax Planning
Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more
1/12/2023
/ Charitable Donations ,
Conservation Easements ,
Federal Budget ,
Internal Revenue Code (IRC) ,
IRS ,
Pass-Through Entities ,
Regulatory Reform ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Reform
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
Earlier this year, the Department of Justice filed the first criminal indictment of promoters, appraisers and accountants connected to an alleged scheme to create syndicated conservation easements. The move followed increased...more