In Conservation Easement Cases, Appeals Is Not So Independent

Publication: Tax Notes Federal, June 16, 2025

The Taxpayer First Act rebranded the IRS Office of Appeals as "Independent" to guarantee taxpayers a fresh, impartial review.

William Stone examines Appeals' plan to offer a uniform conservation easement settlement that mirrors Examination's terms without reviewing individual cases. He compares the IRS's three settlement offers side by side and shares his firsthand experience in docketed Appeals conferences, where offers remained far worse than the published settlement.

He warns that letting enforcement priorities dictate Appeals outcomes sets a precedent that could reach any transaction the IRS targets next.

Related services: IRS Appeals · U.S. Tax Court Litigation

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