IRS Opens the Door on Syndicated Easement Settlements: Limited Time Offers Coming

Short summary

The IRS is releasing limited-time settlement offers for syndicated conservation easement disputes, with applications expected soon. Recent Tax Court decisions show continued scrutiny of valuations and partnership structures. Affected partnerships should immediately inventory their positions, governance requirements, and supporting documentation.

• •IRS launching limited-time settlement program for easement disputes under Section 170(h)
• •Recent Tax Court cases show increased disallowance of claims and stricter valuation scrutiny
• •Partnerships must prepare documentation and assess governance/voting feasibility before offers arrive

Generated with AI, which can make mistakes.