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Full-Text Articles in Law

Ground Zero: The Irs Attack On Syndicated Conservation Easements, Beckett G. Cantley, Geoffrey C. Dietrich May 2021

Ground Zero: The Irs Attack On Syndicated Conservation Easements, Beckett G. Cantley, Geoffrey C. Dietrich

William & Mary Environmental Law and Policy Review

On June 25, 2020, the Internal Revenue Service (“IRS”) announced a settlement initiative (“SI”) to certain taxpayers with pending docketed cases involving syndicated conservation easement (“SCE”) transactions. The SI is the current culmination of a long series of attacks by the IRS against SCE transactions. The IRS has recently found success in the Tax Court against SCEs, but the agency’s overall legal position may be overstated. It is possible that the recent SI is merely an attempt to capitalize on leverage while the IRS has it. Regardless, the current state of the law surrounding SCEs is murky at best. Whether …


Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status May 1973

Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status

William & Mary Law Review

No abstract provided.


Planning And Research: Its Evolution And Role In The Internal Revenue Service, Sheldon S. Cohen May 1968

Planning And Research: Its Evolution And Role In The Internal Revenue Service, Sheldon S. Cohen

William & Mary Law Review

No abstract provided.