SCETs: Do Tax Court Valuations Reflect Government Rhetoric?

Publication: Tax Notes Federal, August 28, 2023

The IRS and Justice Department have long described syndicated conservation easements as built on willfully false valuations. William Stone tests that claim against the record.

Looking only at cases where the Tax Court reached value without finding a technical flaw, he finds the court upheld about 81 percent of claimed deductions, roughly $100.7 million of $123.3 million, and 93 percent in the one fee simple donation it valued.

He explains why technical arguments have dominated and predicts the IRS will be forced into genuine valuation disputes.

Related services: Valuation Disputes · U.S. Tax Court Litigation

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