A Georgia landowner claimed a $23 million tax deduction for a 103-acre conservation easement; an appeals court upheld a valuation of just $480,000 and a 40% penalty after rejecting the property’s proposed quarry value
- Posted on September 25, 2026
- By The Times of India
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- 1 min read
In brief
A Georgia property owner's ambitious $23 million tax deduction for a conservation easement donation faced judicial scrutiny. The IRS and courts rejected the taxpayer's valuation methodology, which assumed the land's highest and best use was quarry extraction. Ultimately, an appeals court upheld a significantly lower $480,000 valuation while imposing a substantial 40% penalty for overstatement, highlighting the importance of accurate appraisals in charitable tax deductions.
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A Georgia landowner claimed a $23 million tax deduction for a 103-acre conservation easement; an appeals court upheld a valuation of just $480,000 and a 40% penalty after rejecting the property’s proposed quarry value
A Georgia landowner claimed a $23 million charitable tax deduction after donating a conservation easement over 103 acres of land. The valuation was based on the argument that the property’s 'highest and best use' before the easement was as an aggregate quarry.
