October 23, 2020
Attorneys continue to flood the Tax Court with petitions challenging the IRS’s denial of conservation easement deductions, with the latest batch of filings comprising nearly $482 million in contested deductions.
The recent wave of easement petitions “is likely the tip of the iceberg,” William E. Ellis of William E. Ellis & Associates LLC told Tax Notes.
Ellis noted that the latest petitions all deal with easements donated in 2016. With recent IRS data showing that the number of easement deals has increased despite the agency’s efforts to curb perceived abuse, taxpayers will likely continue to challenge denied deductions in court over the next several years, he said.