Case Summary:

Oconee Landing Property, LLC v. Commissioner of Internal Revenue is an Eleventh Circuit appeal from a U.S. Tax Court decision disallowing most of a large charitable deduction and imposing penalties arising from a syndicated conservation easement transaction.

In the Tax Court (lower court), Oconee Landing Property, LLC claimed about $20.67 million in charitable contribution deductions for donating a conservation easement over roughly 355 acres in Greene County, Georgia to a qualified land trust, but the IRS disallowed the deduction and issued penalties, and the Tax Court (Lauber, J.) held that the easement’s fair market value was under $5 million, denied most of the claimed deduction, and imposed a 40% gross valuation misstatement penalty plus a 20% accuracy‑related pena ...