Tax Court Rejects Argument Easement Decision Was ‘Predetermined’

A partnership failed to identify any unusual circumstances or substantial errors to warrant reconsidering an earlier decision upholding the government’s dramatic reduction in a conservation easement’s valuation, a US Tax Court judge said.

Judge Emin Toro held in November that the IRS properly determined Paul-Adams Quarry Trust LLC’s donation of a conservation easement on 207 acres in Georgia was worth $612,000 rather than the partnership’s claimed $10.2 million.

In a Jan. 9 decision on Paul-Adams’ reconsideration motion, Toro denied the partnership’s assertions that his opinion was inconsistent with the limited stipulation between the parties and omitted evidence that conflicted with ...