Conservation easements have produced one of the most prolonged tax enforcement campaigns in modern IRS history. SECURE 2.0 §605 codified Notice 2017-10's framework ⁴, effectively capping syndicated conservation easement deductions at 2.5 times contribution. The IRS's Office of Promoter Investigations and the Department of Justice have pursued aggressive criminal cases against promoters. The Tax Court has issued a steady stream of decisions disallowing deductions and imposing accuracy-related and fraud penalties. For our family-business and high-net-worth clients who have used conservation easements, we are now in the post-crackdown landscape, where legitimate easements still work and syndicated transactions are essentially closed.
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