On July 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Village at Effingham LLC v. Commissioner (T.C. Memo. 2020-102). The primary issue before the court in Village at Effingham LLC v. Commissioner was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of a conservation easement in full because the conservation purpose underlying the easements was not “protected in perpetuity” as required by IRC § 170(h)(5)(A),

On June 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Lumpkin HC LLC v. Commissioner (T.C. Memo. 2020-95). The primary issue before the court in Lumpkin HC LLC v. Commissioner was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of a conservation easement in full because the conservation purpose underlying the easements was not “protected in perpetuity” as required by IRC § 170(h)(5)(A), insofar as

On June 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Lumpkin One Five Six LLC v. Commissioner (T.C. Memo. 2020-94). The primary issue before the court in Lumpkin One Five Six LLC v. Commissioner was whether the IRS properly disallowed the charitable contribution deduction with respect to the donation of a conservation easement in full because the conservation purpose underlying the easements was not “protected in perpetuity” as required by IRC