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The Conservation Easement Controversy: IRS Attacks, Taxpayer Victories, and New Guidance

Contains material from Feb 2024

The Conservation Easement Controversy: IRS Attacks, Taxpayer Victories, and New Guidance
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The IRS has been attacking partnerships that make easement donations in many ways, including making them listed transactions, launching a Compliance Campaign, seeking injunctions, placing them on the “dirty dozen” list, litigating numerous Tax Court cases, and more. Things have started to change, though, with several taxpayer victories, issuance of proposed regulations, enactment of a new law taking effect in 2023, and release of safe harbors for deeds. This presentation, made by an attorney who defends hundreds of easement disputes, explores IRS attacks, taxpayer defenses, important court decisions, and what to expect next.

Includes: Video Audio Paper Slides

  • Total Credit Hours:
  • 1.00
  • Credit Info
  • TX, CA
  • TX MCLE credit expires: 2/28/2025

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1. The Conservation Easement Controversy: IRS Attacks, Taxpayer Victories, and New Guidance
(Feb 2024)

Hale E. Sheppard

1.00 0.00 0.00 1.00
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Session 1 —55 mins
1.00
The Conservation Easement Controversy: IRS Attacks, Taxpayer Victories, and New Guidance
(Feb 2024)

The IRS has been attacking partnerships that make easement donations in many ways, including making them listed transactions, launching a Compliance Campaign, seeking injunctions, placing them on the “dirty dozen” list, litigating numerous Tax Court cases, and more. Things have started to change, though, with several taxpayer victories, issuance of proposed regulations, enactment of a new law taking effect in 2023, and release of safe harbors for deeds. This presentation, made by an attorney who defends hundreds of easement disputes, explores IRS attacks, taxpayer defenses, important court decisions, and what to expect next.

Originally presented: Dec 2023 Taxation Conference: Day 1 - Focus on Business Planning

Hale E. Sheppard, Chamberlain Hrdlicka - Atlanta, GA