Prepare a memo that  briefly discusses the rules governing charitable deductions for conservation easements.

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Tax 625 – Research Paper

Your new client is an investor in a syndicated conservation easement. The related charitable

contribution deduction claimed on the individual 1040 was entirely disallowed following the IRS’s

examination of the tax return. The case is currently pending in Tax Court.

The client has learned the IRS has offered to settle these cases. The offer follows a string of IRS

victories over investors and the related partnerships formed to purchase property for the

purpose of donating a conservation easement to an exempt organization. The IRS considers

these “abusive” transactions.

Prepare a memo that  briefly discusses the rules governing charitable deductions for

conservation easements. Your memo must (2) discuss at least 3 recent court cases where the

IRS has challenged those deductions in court. Take note: a number of the recent IRS “victories”

in the SCE cases are currently on appeal (and may, perhaps, be reversed).

After your review of the applicable cases and authorities, (3) summarize the advantages and

disadvantages of the IRS settlement offer.

Finally, (4) do you recommend that the client accept the settlement or continue to challenge the

disallowance (even if it requires litigation). You should justify whichever option you advise your

client to undertake.

 

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