Georgia Partnership Challenges IRS $78 Million Easement Denial

The IRS incorrectly rejected a $77.9 million deduction for a conservation easement prohibiting future excavating, dredging, mining, and drilling because the agency failed to properly evaluate the land, a Georgia partnership told the US Tax Court.

Wildcat Quarry LLC donated a conservation easement on approximately 136 acres in Gilmer County, Ga. and claimed a noncash charitable contribution deduction on its 2021 tax return, according to its Feb. 10 petition. The final partnership adjustment issued by the IRS in November 2025 said the easement was worth nothing because Wildcat Quarry didn’t establish the non-cash charitable contribution’s value was greater than ...