On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of land to taxpayers looking for large tax deductions. The taxpayers get allegedly inflated appraisals of those tracts of land and grant conservation easements on that land. The resulting charitable deductions are then split among the taxpayers.
Fourteen separate letters were sent to individuals who appear to be associated with the promotion of syndicated ...
The Tax Court recently issued a full T.C. opinion which will impact a tremendous number of conservation easement donations. In Pine Mountain Preserve, LLLP v. Commissioner, 151 T.C. 4 (2018) the Tax Court found a reservation of rights to construct certain improvement within a floating building envelope resulted in a conservation easement failing to constitute a qualified real property interest granted in perpetuity. As a result, no deduction was allowed for the grant of the conservation easement.
Taxpayers have commonly reserved the right to construct improvements within a ...