IRS targets syndicated conservation easements

Description

Abstract: The IRS has issued a notice warning taxpayers that it considers certain syndicated conservation easement transactions that offer investors significant charitable deductions to be “tax avoidance transactions,” otherwise known as unlawful tax shelters. Taxpayers involved in such a transaction — or a “substantially similar” transaction — may be at risk for an audit, the denial of charitable deductions and the imposition of substantial underpayment penalties. This article summarizes IRS Notice 2017-10. RP Golf, LLC v. Comm’r, No. 2016-80, April 28, 2016 (Tax Ct.)