Real Estate Firm Fights $43.1 Million Historic Easement Refusal

A real estate development firm is fighting the IRS’ rejection of a $43.1 million charitable contribution deduction tied to a historic preservation easement, telling the US Tax Court in a new petition that the agency failed to substantiate the decision.

Liberty Landmark Group LLC said in its Feb. 2 petition that the IRS’ assertions are contrary to both the facts established during an audit of its 2016 tax return and applicable law. Liberty Landmark serves as the tax matters partner for GBX Group LLC, which acquires and preserves historic real estate across the US.

In a conservation easement, a land ...