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Should You Invest In A Syndicated Conservation Easement ?

The value of an easement is the fair market value of property before the easement less the value of the property as encumbered by the easement.  The industry argues that the procedure for determining the before FMV is different in the case of the easement.  It is not.  Given that the market for undeveloped land, imperfect as it may be, is not populated with idiots, promoters cannot routinely acquire properties and have them in relatively short order be worth a multiple of what they acquired them for..  That’s why I think the industry is based on nonsense.

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IRS Successfully Attacks Tax Shelter With Hobby Loss Rule

IRS Successfully Attacks Tax Shelter With Hobby Loss Rule

So the lenses were never actually placed in service.  There were basis issues with the way they were financed.  There was no meaningful participation by the Olsens to satisfy the requirements of Section 469.  Other than that Mrs. Lincoln how did you enjoy the play? Well there is also 183 to worry about.

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Over and over again courts have said that there is nothing sinister in so arranging one’s affairs as to keep taxes as low as possible. Everybody does so, rich or poor; and all do right, for nobody owes any public duty to pay more than the law demands: taxes are enforced exactions, not voluntary contributions. To demand more in the name of morals is mere cant.