A Year in Review: The Nondocketed Settlement Program for Syndicated Conservation Easements
Oct 20
1 min read
Updated: Oct 26
Publication: Tax Notes Federal, September 22, 2025
Drawing on hands-on experience, William Stone follows the IRS's 2024 nondocketed settlement program through its four phases: offer, waiting, closing agreement, and completion.
He documents the practical problems taxpayers faced, including a 30-day decision window, offers with no stated amount owed, divided partner votes, and two closing agreements for the same partnership that differed by more than $700,000. He also covers the IRS's refusal to consider counteroffers.
The article closes with two changes that could have made the program work: collecting at the partner level and stating the amount owed up front.
Related services: IRS Audits & Examinations · IRS Appeals
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