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On Dec. 6, 2022, the IRS issued proposed regulations identifying syndicated conservation easement transactions as listed transactions for purposes of I.R.C. § 6011. ....
Following defeat in Tax Court cases of Administrative Procedure Act, IRS issues proposed regulations identifying syndicated conservation easement transactions as listed transactions. This shows the IRS is taking a proactive approach in addressing the APA challenges. ....
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159. ....