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THE SPLIT DOLLARMINATOR!
In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more
In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
Judge Batten, Chief United States District Judge for the Northern District of Georgia, handed down lengthy sentences in the first-of-its-kind criminal trial related to syndicated conservation easements (“SCEs”). On January...more
On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more
Last week, the first federal criminal trial related to syndicated conservation easement (“SCE”) deals began with impaneling the jury and opening statements. Each of the Fisher defendants on trial, Jack Fisher, James Sinnott,...more
The first criminal prosecution of syndicated conservation easement promoters began on July 18, 2023, with the government laying out its case against defendants Jack Fisher, James Sinnott, and Clayton Weibel. A Department of...more
Polsinelli’s Government Investigations and Tax attorneys continue to follow the well-known Fisher case, the Department of Justice’s (“DOJ”) first criminal indictment related to syndicated conservation easements. The trial is...more
On Dec. 29, 2022, the United States Congress passed the SECURE 2.0 Act of 2022 (SECURE Act 2.0). Section 605(d) of the SECURE Act 2.0 gave conservation easement donors a safe harbor to amend provisions relating to...more
Polsinelli’s Government Investigations and Tax attorneys continue to follow the well-known Fisher case, the Department of Justice’s ("DOJ") first criminal indictment related to syndicated conservation easements. Walter...more
Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more
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
Tax Litigation: The Week of December 19th, 2022, through December 23rd, 2022 Starer v. Comm’r, T.C. Memo. 2022-124 | December 20, 2022 |Wells, J. |Docket No. 615-13 Mamadou v. Comm’r, T.C. Memo. 2022-121 | December 20, 2022...more
At the end of the year, many people think about giving to charities, especially people who are seeking additional tax deductions. In fact, statistics show that as much as 30% of charitable giving is done in the last month of...more
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more
A trial before the United States Tax Court recently determined the value of a conservation easement imposed on a Georgia golf course which was being contested by the Internal Revenue Service. Relying on the “before and after”...more
On September 21, 2022, the New York State Attorney General Tish James filed a civil lawsuit against former President Donald Trump and the Trump organization alleging fraud and misrepresentation. The Complaint described a...more
Earlier this year, the Department of Justice filed the first criminal indictment of promoters, appraisers and accountants connected to an alleged scheme to create syndicated conservation easements. The move followed increased...more
Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Domdom v. Comm’r, T.C. Summary Opinion 2022-17 | August 30, 2022 | Carluzzo, J. | Dkt. No. 18270-17S Pressman v. Comm’r, T.C. Summ. Op. 2022-15 |...more
Tax Litigation: The Week of July 18th, 2022, through July 22nd, 2022 Pettennude v. Comm’r, T.C. Memo. 2022-79 | July 18, 2022 | Buch, J. | Dkt. No. 636-21L Gonzalez v. Comm’r, T.C. Summary Opinion 2022-13 | July 18, 2022 |...more
On May 2, 2022, the Wall Street Journal published two detailed articles authored by Richard Rubin on the subject of syndicated conservation easements: Conservation Tax-Break Deals Keep Flowing Despite IRS Crackdown (WSJ...more
Tax Litigation: The Week of March 21, 2022, through March 25, 2022 Oxbow Bend, LLC v. Comm’r, T.C. Memo. 2022-23 | March 21, 2022 |Lauber, J. | Dkt. No. 12718-19 Short Summary: This case involves a charitable contribution...more
Joint Committee on Taxation Report on Tax Treatment of Charitable Contributions - On March 11, 2022, the Joint Committee on Taxation published its 49-page report (the “Report”) relating to the federal tax treatment of...more
Tax Litigation: The Week of March 14, 2022, through March 18, 2022 Hamilton v. Comm’r, T.C. Memo. 2022-21 | March 15, 2022 |Urda, J. | Dkt. No. 139-19L AptarGroup, Inc. v. Comm’r, 158 T.C. No. 4 | March 16, 2022 |Goeke, J. |...more