Deduction for easement denied for wrong termination formula
The Internal Revenue Service has won another battle against deductions for conservation easements it believes are unjustified. The Tax Court has denied a deduction for an easement that includes an improper formula on what happens to the proceeds if the property is ultimately sold and the easement terminated. Sage Mill Investment Property Two, Ltd. acquired 454 acres of land in Aiken County, SC, for about $4 million in 2008. Through a series of transactions the property became owned by a new limited liability company owned primarily by an investment fund. The new LLC transferred a conservation easement to the Southeast Regional Land Conservancy and claimed a charitable contribution deduction...
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