Question
The taxpayers earned $80 million per year and purchased an estate for 48 million. the first appraiser's conservation easement had a fair market value of
The taxpayers earned $80 million per year and purchased an estate for 48 million. the first appraiser's conservation easement had a fair market value of $49 million, and the second appraiser took the position that the conservation easement had a fair market value of $38 million. The taxpayers donated a perpetual for 49 million.
The IRS disallowed a charitable deduction for the gift of the conservation easement in its entirety. The IRS alleged civil fraud based on the appraisal.
What are the deduction issues and penalties issues?
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