by admin | Sep 11, 2021 | Tax
The IRS Chief Counsel has signaled with CCA 202130014 that the Service will be continuing its hard line on conservation easements. The engine of every abusive syndicated conservation easement is a vastly inflated appraisal. Rather than focus on the appraisal issue,...
by admin | Jul 7, 2021 | Tax
The Eleventh Circuit has dealt a blow to the beleaguered syndicated conservation easement (SCE) industry in its decision upholding the Tax Court in TOT Property Holdings LLC v IRS. As I have noted elsewhere SCE is an industry based on nonsense. Investors buy into a...
by admin | Jun 29, 2021 | Tax
DOJ is sending a message to tax professionals – particularly CPAs – who are involved in the syndicated conservation easement (SCE) industry. The message is “Be afraid. Be very afraid.” That is my reading of a recent press release about...
by admin | Apr 29, 2021 | Tax
Another class action lawsuit is hitting the beleaguered syndicated conservation easement industry. As in the other three, which are covered here, here and here, David Deary is the lead attorney. The case is Hoover et al v Strategic Capital Partners, LLC et al and...
by admin | Apr 18, 2021 | Tax
Finally the syndicated conservation easement (SCE) empire strikes back. Battered in Tax Court by the IRS, hounded by the Department of Justice seeking criminal charges and injunctions and beleaguered by class action attorneys SCE appraisers are fighting back with a...
by admin | Apr 15, 2021 | Uncategorized
If you invested in a syndicated conservation easement that had Nancy Zak of Forever Forests as one of the consultants, you should be hearing from her soon. And you won’t like what she tells you. Ms. Zak is one of the defendants in a major Department of Justice...
by admin | Jan 19, 2021 | Tax
Originally published on Forbes.com. Things have not been great for the syndicated conservation easement (SCE) industry. Late in December, two accountants who focused on SCE pled guilty to conspiracy. The circumstances of their pleas indicate that they are cooperating...
by admin | Nov 30, 2020 | Tax
Originally published on Forbes.com. There is a sign that the IRS is raising the stakes in its attack on syndicated conservation easements (SCE). Jennifer Black, (Senior Counsel Procedure and Administration) authored two chief counsel advices CCA 202044009 and...
by admin | Nov 19, 2020 | Tax
Originally published on Forbes.com Judge Robert Goeke of the United States Tax Court approved a $17.5 million 2012 charitable deduction disallowance in the case of Glade Creek Limited Partnership. He went a little easier on the penalties than the IRS had proposed. ...
by admin | Oct 17, 2020 | Tax
Originally published on Forbes.com. Senators Grassley, Daines and Roberts have introduced a bill to “end abuse of conservation easements”. The Charitable Conservation Easement Program Integrity Act of 2020 is an update to a previously introduced bill that has been...
by admin | Oct 7, 2020 | Tax
Originally published on Forbes.com. There is no such thing as bad publicity. That may be what is proved by the continuing growth of the syndicated conservation easement industry in 2018 in the face of dire warnings from the IRS. According to a recent IRS report...
by admin | Sep 13, 2020 | Tax
Originally published on Forbes.com. The Senate Finance Committee report- Syndicated Conservation-Easement Transactions – released on August 25 is very heartening. It exposes tax shenanigans that threaten an otherwise benign tax incentive. At least it is as...
by admin | Sep 11, 2020 | Tax
Originally published on Forbes.com. In the wake of last week’s damning report from the Senate Finance Committee, the IRS is crowing over the first opponent to throw in the towel in a Tax Court brawl over a syndicated conservation easement based on the IRS offer...
by admin | Aug 31, 2020 | Tax
Original Your Tax Matters Partner material by Peter J. Reilly The Senate Finance Committee report on syndicated conservation easement transactions released on August 25, 2020, is a dramatic development. I have been covering conservation easement tax deductions for...
by admin | Aug 15, 2020 | Tax
Originally published on Forbes.com Belair Woods LLC (TCM 2020-112, July 22, 2020) is one of a flurry of Tax Court decisions on conservation easements that have been flying through the Tax Court. I understand that there are a lot more coming. It is the third decision...
