Jasen Hanson’s article in Bloomberg Tax discusses the IRS settlement programs for taxpayers with pending conservation easement cases.
In an article published in Bloomberg Tax on December 3, 2024, Atlanta-based Shareholder Jasen Hanson discussed issues with syndicated conservation easements regulations and how taxpayers should navigate their cases.
He explains how earlier this year, the IRS sent multiple waves of letters to taxpayers with pending conservation easements in the Tax Court that offered to settle their cases. “Over the summer, the IRS began sending letters offering a variation of the standard settlement terms for non-docketed cases still under examination. This version kept the prohibition on Section 170 deductions and cash-basis “other deduction,” but it reduced the gross valuation misstatement penalty to 5% and creates a fictitious partnership-level tax of 21% (as opposed to the potential 37% rate),” Hanson writes.
Hanson illustrates what taxpayers should now consider, “Taxpayers and their advisers then must analyze the cost of proceeding to trial. Expert witness fees and a cadre of IRS lawyers creating paperwork means a trial on the merits can be a costly endeavor that dwarfs the potential benefits.”
To review the full article, you may click here.