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

June 29, 2020

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%.