Tax Notes has published an article by three authors, Scott D. McClure, Steven E. Hollingworth, and Nicole D. Brown of Hogan and Hartson, LLP. McClure is a partner at the firm who focuses on corporate transacations and state tax issues, Hollingworth and Brown are associates the the firm, both focusing on assorted tax issues. The authors propose that courts are generally rejecting the IRS's zero valuation assessment of conservation easements, and moreover the courts are finding significant value in such easements. A conservation easement generally refers to a legal agreement in which the owner of a property agrees to set aside some property for conservation/environmental purposes. The IRS believes such easements should not be deductible without appropriate scrutiny and investigation.
See Scott D. McClure, Steven E. Hollingworth, and Nicole D. Brown, "Courts to IRS: Ease Up on Conservation Easement Valuations," 7 2009 TNT 151-7, July 14, 2009.
Posted by Raj Chudgar, Associate Editor, Wealth Strategies Journal
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