IRS Got Right Approvals to Nix $24 Million Conservation Easement

The IRS properly obtained supervisory approvals when it denied a $24.4 million conservation easement, the US Tax Court said.

Judge Albert G. Lauber rejected arguments that the US Court of Appeals for the Eleventh Circuit created more stringent requirements for the IRS to penalize companies under IRC Section 6751(b)(1), and that the agency failed to follow them when assessing penalties to Ivey Branch Holdings LLC.

Ivey Branch claimed a conservation easement for a 141-acre Georgia tract for its 2015 tax year, and petitioned the Tax Court when the government subsequently disallowed and imputed penalties. A conservation easement allows a ...