30 Wrongs Do Not Make a Right: Revealing Extraordinary IRS Actions in Conservation Easement Disputes



The IRS believes that partnerships that engage in syndicated conservation easement transactions (“SCETs”) are claiming excessive tax deductions. The partnerships, on the other hand, point to congressional support for over 50 years, large amounts of pre-donation due diligence, full disclosure to the IRS, and reliance on a long list of experts. The two sides simply disagree, which is fine. What is not okay, though, is that in attacking SCETs, the IRS is utilizing extraordinary tactics that might negatively affect all taxpayers. The article suggests that those concerned about taxpayer rights, separation of powers, environmental protection and other large-scale matters might question whether numerous “wrongs” by the IRS are achieving a “right.”


About Hale E. Sheppard

HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

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