A partnership connected to a Mississippi equity firm urged the US Tax Court to find the IRS has unfairly disallowed its $88 million tax deduction for preserving a large tract of land in Kentucky.
KYRock LLC, which is organized by Oxford, Miss.-based real estate investor Rubicon Capital LLC, donated a conservation easement on 137 acres of land in central Kentucky, but the IRS determined the donation wasn’t legitimate for tax purposes and didn’t meet the requirements of IRC Section 170, it said in a petition to the US Tax Court filed Oct. 2.
The IRS found the partnership underpaid ...