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Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more
Syndicated Conservation Easements - In an IRS news release of January 17, 2022, the IRS’s Office of Chief Counsel announced that plans to hire up to 200 additional attorneys “to help the agency combat syndicated...more
The Internal Revenue Service (“IRS”) issued a November 12th announcement titled: IRS Increases Enforcement Action on Syndicated Conservation Easements (“Memorandum”) - ...more
In Notice 2017-10, the Internal Revenue Service recently issued guidance on syndicated conservation easement transactions presumed to be used as tax shelters. This addition to the “listed transactions” under Section...more
In Notice 2017-10, the IRS has determined that certain conservation easements are now “listed transactions” for purposes of federal tax reporting. “Syndicated” conservation easements are conservation easements donated by a...more