About the Course
Introduction
This CLE/CPE course will guide tax counsel and advisers on critical tax issues concerning valuations for easement transactions stemming from recent tax court cases. The panel will discuss legal theories and IRC provisions highlighted in recent tax court cases, IRS enforcement actions, and managing IRS examinations
Description
A conservation easement is a legally enforceable perpetual land preservation agreement between a landowner and either a government agency or a qualified land protection organization (such as a land trust) for the conservation of the land and its resources. Grantors within these transactions can take advantage of significant tax benefits so long as the easement meets IRS approval where there is a donation.
Typically, charitable deductions are not allowed for these transactions, but IRC Sections 170(h)(1) through (h)(5) and Treas. Reg. 1.170A-14 provide for an exception. A charitable contribution deduction is allowed for the fair market value of the conservation easement donated to certain charitable organizations, subject to a limitation on the amounts.
IRS enforcement actions on conservation easement transactions force taxpayers, tax counsel, and advisers to identify and recognize key tax issues in these transactions. Recent tax court cases focused on easement valuation methods, such as Hancock County Land Acquisitions L.L.C. v. Commissioner, have resulted in significant penalties for overvaluing conservation easements.
Listen as our panel discusses critical elements in conservation easement valuations, minimizing IRS assessments and audits, and recent IRS enforcement actions, as well as offers techniques in defending conservation easement transactions.
Presented By
Mr. Wiggam is a founding partner of Wiggam Law in Atlanta, Georgia. His practice focuses on representing individuals, businesses, officers, directors, shareholders, and partners in matters concerning the Internal Revenue Service (IRS), the Georgia Department of Revenue, and other state tax departments. Mr. Wiggam has successfully represented clients in the IRS’s recent crackdowns on syndicated conservation easements and micro-captive insurance disputes. He also has significant experience handling IRS tax settlements, tax compliance, appeals representation, offshore foreign bank reporting compliance, audit representation from responding to IRS audit letters through to IRS audit reconsiderations, if necessary, innocent spouse relief, IRS levy and IRS garnishment releases, penalty waivers/abatements, and lien releases/withdrawal.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Date + Time
- event
Thursday, May 21, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Benefits and limitations of conservation easements
II. Tax benefits for donors and applicable tax regulations
III. Valuation requirements
IV. Recent tax cases and IRS enforcement actions
V. Key considerations and options for investors
The panel will review these and other crucial issues:
- What are the key tax considerations for structuring conservation easements?
- What are the most common methods of attack on easement deductions?
- What are the income and estate tax regulations applicable to conservation easement transactions?
- What are the requirements for the valuation of easements?
- What are the penalties for valuation misstatements?
- What is the status of recent case law and legislative developments related to conservation easements, and what can practitioners expect moving forward?
- What options do investors have to mitigate their tax exposure at the federal and state level?
Related Courses
IRC Section 338(h)(10) and 336(e) Election Strategies for Tax Counsel
Tuesday, August 4, 2026
1:00 p.m. ET/10:00 a.m. PT
