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Tax Coda

Tax Court Slashes $10 Million Easement Deduction to $612,000

Paul-Adams Quarry Trust, LLC v. Commissioner (Tax Court 2025)

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Tax Coda
Nov 04, 2025
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The Tax Court valued a 2017 conservation easement at $612,000 and imposed the 40% gross valuation misstatement penalty after rejecting the partnership’s $10,234,108 claimed value.

Holding

The easement’s fair market value was $612,000, not $10,234,108. The appraisal attached to the return met the “qualified appraisal” requirement because the appraiser was …

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