Appeals Court Wary of Reversing Conservation Easement Ruling (1)

A federal appeals court panel appeared dismissive Wednesday of a Georgia partnership’s claim that the US Tax Court ignored the “reasonable person standard” before affirming a denial of its $20.7 million conservation easement deduction.

Judges on the US Court of Appeals for the Eleventh Circuit panel expressed skepticism toward Oconee Landing Property LLC’s valuation of its 355-acre conservation easement, despite the Tax Court’s finding that the partnership wasn’t entitled to the deduction because it failed to include a qualified appraisal.

“Because it’s a finding of fact, we have to review it for clear error,” Chief Judge William H. Pryor Jr. ...