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SCETs: Do Tax Court Valuations Reflect Government Rhetoric?


The IRS has continuously targeted syndicated conservation easement transactions (SCETs) for their alleged overvaluation of donated property. William Stone III, associate in MMM’s Tax Controversy practice group, recently wrote a white paper published in the August 28, 2023, issue of Tax Notes Federal exploring such issue.

Stone writes that in the few cases in which the Tax Court has ultimately valued an SCET and what the IRS declares to be a “substantially similar transaction,” transactions with no technical flaws have not been based on “willfully false values.”

Read the full article here. A Tax Notes subscription is required.