The IRS wrongly rejected nearly $163 million in charitable contribution deductions that a pair of partnerships took in 2020 for donating conservation easements on hundreds of acres of land in Texas, they told the US Tax Court in separate petitions.
Olive Farm LLC and Cayacoa Bay LLC—both units of real estate company EcoVest Management LLC—contested the IRS’s decision that neither satisfied the requirements for charitable deductions established under IRC Section 170 and corresponding Treasury Regulations, showed the value of the contributions exceeded $0, or proved that the transactions should be respected for federal income tax purposes.
The companies challenge the ...