Settling Syndicated Conservation Easement Cases with the IRS


There is a method the IRS often uses to combat transactions it opposes. The precise steps vary, but it generally entails warning the public, labeling items “abusive,” conducting lots of audits, forcing weak cases to trial quickly to obtain favorable court decisions, introducing settlement programs with terms designed to tempt risk-averse taxpayers, and encouraging Congress to make legislative changes. Does this sound familiar? It sure does to those involved with conservation easements, with one exception. When it comes to easements, the IRS has been launching settlement programs for years, which, for different reasons, have made resolving matters before trial unappealing and/or impractical for many partnerships. This article, which expands on earlier ones, examines challenges with three IRS settlement programs.

Read the full article here.

About Hale E. Sheppard
HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a partner at Eversheds Sutherland.  He defends clients in tax audits, tax appeals, and Tax Court litigation, covering both domestic and international issues.

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