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ARTICLE · 24 JUNE 2022

Conservation Deeds And Consistency With Treasury Regulations

Freeman Law
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Morgan Run Partners, LLC ("Morgan" or "Petitioner") petitioned the Tax Court for readjustment of partnership items after the IRS disallowed a deduction and assessed penalties.

United StatesLitigation, Mediation & Arbitration
Micah Miller
Micah Miller

Morgan Run Partners, LLC, Overflow Marketing, LLC, Tax Matters Partner v. Comm'r, T.C. Memo. 2022-61 | June 14, 2022 | Lauber, J. | Docket No. 8669-20

Short Summary: Morgan Run Partners, LLC ("Morgan" or "Petitioner") petitioned the Tax Court for readjustment of partnership items after the IRS disallowed a deduction and assessed penalties. The IRS disallowed Morgan's charitable contribution deduction for a syndicated conservation easement, which it claimed on a timely Form 1065 and supported with an appraisal.

>Morgan granted to the National Farmer's Trust (the "Trust") a conservation easement over 232 acres of land. Petitioner timely filed a return and for 2016 and a deduction of $26 million for donation of the easement. The IRS then selected Morgan's return for an examination. The Revenue Agent (RA) recommended assessing penalties under IRC sections 6662 and 6662A. Her manager agreed and signed an approval form in September of 2019. In late October the RA

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