Old Offer, New Packaging: The IRS's Latest Conservation Easement Initiative

Publication: Tax Notes Federal, June 29, 2026

In May 2026 the IRS announced a settlement initiative for more than 1,100 conservation easement cases under audit or in the Tax Court.

William Stone argues the offer largely formalizes terms already extended to docketed cases, so it is unlikely to reduce the backlog much. He examines the terms, the one-size-fits-all design that can leave non-syndicated donors with a zero deduction, the exclusion of cases bound to a test case, and timing gaps that pushed some taxpayers into trial before the offer arrived.

He concludes that real progress requires reviewing each case on its own facts.

Related services: IRS Appeals · IRS Audits & Examinations

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