Georgia landowner loses $23m tax break challenge in appeals court
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A US appeals court upheld a $480,000 valuation for a conservation easement that a Georgia landowner had claimed was worth $23 million.
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The brief
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- A company claimed a $23 million tax deduction for a conservation easement on 103 acres of land in Georgia.
- The valuation relied on the argument that the property could have been used as an aggregate quarry.
- The US Tax Court and an appeals court both rejected the quarry valuation as not financially feasible due to market competition.
- The court assigned a value of $480,000 to the easement and upheld a 40% gross valuation misstatement penalty for the significant overstatement.
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NamedUnited States · Savannah Shoals · 11th Circuit US Court of Appeals · Hart County · Internal Revenue Service · US Tax Court
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