Our goal is to spread the truth about the tax code, how people get it right, and where they go wrong.

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Promoting Conservation Through Education

Our mission is to educate the public about the importance of conservation easements under Section 170(h) of the U.S. Tax Code. Congress created conservation easements to encourage private landowners to preserve their land for the public good. Since that time, over 40 million acres have been protected by conservation easements.1

Together, we can spread awareness about this critical conservation tool and inspire action to safeguard America’s natural beauty. Learn, engage, and help us keep America beautiful for generations to come.

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March 28, 2024

Title: Ruling in favor of Valley Park Ranch, LLC finding Oppenheimer easement deed  satisfies statutory requirements.

Publisher: United States Tax Court

This case involves Valley Park Ranch, LLC (Valley Park) claiming a $14.8 million deduction for a conservation easement it donated in 2016. The IRS disallowed the deduction, leading to a petition to the United States Tax Court. The main issue was whether the easement deed met the requirements of Internal Revenue Code (IRC) section 170(h) and Treasury Regulation § 1.170A-14(g)(6)(ii).

Valley Park’s tax matters partner, Reed Oppenheimer, argued that the deed complied with the statute and regulation, but also challenged the validity of the regulation under the Administrative Procedure Act (APA), or suggested that the deed might be ambiguous…

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April 25, 2023

Title: IRS Accused of Using Backdated Documents to Win Ruling on Penalty Approval 

Publisher: Tax Notes Today 

Author: Kristen A. Parillo 

The IRS is facing accusations of fraud after allegedly submitting backdated penalty approval forms and false declarations to win a ruling on section 6751(b) compliance in the Lakepoint Land II LLC case. The petitioner has filed a motion for reconsideration and a motion to impose sanctions, claiming that the IRS perpetrated a fraud on the Tax Court by failing to alert the court of its misconduct. 

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February 3, 2020

Title: National Taxpayer Advocate Recommends Stronger Safeguards

Publisher: National Tax Payer Union 

Author: Mattie Duppler

The National Taxpayer Advocate (NTA), an independent organization within the IRS that helps taxpayers resolve issues with the IRS and recommends changes to mitigate systemic problems, has recently recommended stronger safeguards for conservation deductions. This comes in response to ongoing debates concerning conservation easements, particularly syndicated conservation easements.

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January 3, 2022

Title: Eleventh Circuit Deals IRS Defeat In Conservation Easement Struggle 

Publisher: Forbes Money Taxes 

Author: Peter J. Reilly 

The Eleventh Circuit has dealt a significant blow to the IRS in its ongoing struggle against abusive conservation easement deductions. In a recent decision, Judge Barbara Lagoa, a Trump appointee, wrote that the IRS regulation on judicial extinguishment formula for conservation easement deductions is invalid.

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