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Responding to Recent Taxpayer Victories, IRS Issues Proposed Regulations Identifying Syndicated Conservation Easement Transactions as Listed Transactions | Insights

Published: December 13, 2022

On Dec. 6, 2022, the IRS issued proposed regulations identifying syndicated conservation easement transactions as listed transactions for purposes of I.R.C. § 6011.

Source: gtlaw.com

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United StatesUs Tax Court On NovTreasury DepartmentTax CourtMann Construction IncBobbya BranchGreen Valley InvestorsAdministrative Procedure ActMann ConstructionSixth CircuitCircuit RulesListing TransactionsRaising QuestionsCiting Mann ConstructionTax Matters PartnerCourt Invalidates Conservation Easement NoticeAbates Reportable Transaction PenaltyConservation Easement Transaction IdentifiedMaterials DefinedHighest Stated Charitable DeductionQualified Organizations Receiving DonationsSyndicated ConservationQualified Organizations Not TreatedQualified Organizations No Longer ExcludedExcise Tax