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In holding that that Treas. Reg. § 1.170A-14(g)(6)(ii) (Proceeds Regulation) is procedurally invalid under the Administrative Procedure Act (APA), the U.S. Tax Court abandoned its...
McLaughlin on Conservation Easements & the Proceeds Regulation Nancy A. McLaughlin (University of Utah S.J. Quinney College of Law) has posted Conservation Easements and the Proceeds Regulation (56 Real Prop. Tr. & Est. L.J. 1 (2021), Forthcoming) on SSRN. Here is the abstract: This article provides an in-depth look at Treasury Regulation § 1.170A-14(g)(6)(ii), known as the proceeds regulation. The proceeds regulation is intended to protect the public investment in conservation if a perpetual conservation easement that was the subject of a charitable deduction under Internal Revenue Code ...