The success of the IRS’s latest attempt to clear the backlog of conservation easement cases will depend on the structure of a settlement offer expected any day.
Previous offers to companies that used syndicated conservation easements—a transaction the agency listed as a Dirty Dozen tax scam in recent years—largely flopped. Large partnerships essentially would buy land and overvalue it, taking charitable contribution deductions that could be more than quadruple their investment.
The IRS is preparing a new offer, though tax controversy attorneys are wary after the agency bungled past incentives by offering differing deals to similar taxpayers, requiring strict deadlines, ...