Case: Taxpayer’s Arguments Did Not Disturb Valuation and Assessment of Conservation Easement, Tax Court Affirmed (11th Cir.) (IRC §170)

The U.S. Tax Court correctly determined the amount of Taxpayer’s overvaluation of a conservation easement based on expert testimony and market analysis determination, held the U.S. Court of Appeals for the Eleventh Circuit, dismissing Taxpayer’s petition for review. Taxpayer, a limited liability company, claimed a $47.6 million charitable contribution deduction for granting a conservation easement on property it owned. The IRS disallowed the deduction and assessed penalties for overvaluation. The Tax Court found that while the easement qualified as a charitable contribution and entitled Taxpayer to a deduction, Taxpayer had grossly overstated its value and was liable for the 40% ...