• videocam Live Webinar with Live Q&A
  • calendar_month May 21, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Conservation Easement Valuations and Taxation: Recent Tax Court Cases, Structuring Transactions, Tax Planning

Qualified Appraisals, Determining a Property's Highest and Best Use, Civil Fraud and Gross Valuation Misstatement Penalties

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MSRP
$347.00
$294.95
Save $52.05

Discount expires 5/7/26

This course is $0 with these passes:

CLE
CPE
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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 critical elements in structuring easement transactions, 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 structuring these transactions. Recent tax court cases focused on easement valuation methods, such as Jackson Crossroads L.L.C. v. Commissioner and 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

John W. Hackney
Chair, Tax Controversy Practice Group
Chamberlain Hrdlicka Attorneys at Law

Mr. Hackney specializes in Federal and state tax controversy matters and tax litigation, including tax-related examinations and administrative appeals involving individuals, business enterprises, partnerships, limited liability companies, corporations and others. He has extensive expertise on a broad variety of both substantive and procedural tax issues often involving sophisticated and complex legal issues including significant Family Office matters, tax penalty abatements, Section 469 passive activity losses, tax issues associated with private aircraft ownership, estate and gift tax valuation issues, captive insurance, syndicated conservation easements, and related activities, Employee Retention Credits (ERC), research and development credits, accounting method issues, Section 1031 “like-kind exchanges”, and Section 183 hobby losses.

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Jason Wiggam
Founding Partner
Wiggam Law

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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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • CPE credit is not available on recordings.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

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. Defending and litigating conservation easement tax matters

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?

Learning Objectives

After completing this course, you will be able to:

  • Recognize the key tax benefits of conservation easements for donors
  • Identify critical tax issues for conservation easement transactions
  • Ascertain the key IRS requirements for conservation easement transactions
  • Acquire effective methods in reporting and defending conservation easement transactions
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .