The IRS has announced a time-limited offer to settle certain syndicated conservation easement cases pending in the U.S. Tax Court.

Eligible taxpayers will be notified by letter about settlement terms. They include that:

1) The deduction for the contributed easement is disallowed in full;
2) All partners must agree to settle, and the partnership must pay the full amount of tax, penalties and interest before settlement;
3) “Investor” partners can deduct their cost of acquiring their partnership interests and pay a reduced penalty of 10% to 20%; and
4) Partners providing services for a syndicated conservation easement transaction must pay the maximum penalty asserted by IRS, typically 40%.