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IRS proposed regulations to identify syndicated conservation easement transactions as listed transactions. U.S. Tax Court held that Notice 2017-10, designated syndicated conservation easement transactions as listed transactions, was invalid and issued in violation of the APA.
Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement.
The U.S. tax system is a "self-assessment" model: upon determining how tax provisions apply to their transactions, taxpayers pay any tax due, and report the transactions to the I.R.S.
U.S. Court of Appeals for the Sixth Circuit ruled in Mann Construction, Inc. v. U.S.1 the IRS must follow the Administrative Procedures Act when identifying listed transactions for purposes of applying the I.R.C. ยง 6707A penalty.