Tax Court’s Conservation Easement Ruling Scrutinized on Appeal

The donation of a 500-acre tract of Georgia land again came under scrutiny Tuesday before a panel of federal appeals court judges, who questioned a lower court’s ruling and whether its owners assigned the proper value when taking a corresponding $14.17 million tax deduction.

Ralph Evans and Nathaniel Carter argued that donating the land—which they said could have been rezoned from agricultural use to a coastal housing development for up to 827 homes and 163 docks—reduced its value. But the IRS rejected their valuation of the conservation easement donation and instead limited it to $1 million.

The case is before ...