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Nathaniel Carter, et al v. Commissioner of Internal Revenue
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August 13, 2026
Split 11th Circ. Backs IRS $1M Value For Contested Easement
A split Eleventh Circuit panel affirmed a decision to slash three Georgia landowners' conservation easement value from $18 million to $1 million Thursday, saying the U.S. Tax Court didn't need to determine the property's best use because the parties already agreed on that use.
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March 06, 2025
IRS Can't Defend Slashing Of Easement Value, 11th Circ. Told
Conservation easement donors whose charitable tax deduction was reduced by millions of dollars by the U.S. Tax Court criticized the Internal Revenue Service's defense of the decision, telling the Eleventh Circuit the ruling ignored copious evidence of the property's value underlying the donation's worth.
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January 14, 2025
Easement Worth $1M, Not $18M, Gov't Tells 11th Circ.
The U.S. Tax Court was right to believe expert testimony that a claimed conservation easement donation of roughly $18 million was only worth $1 million, the government told the Eleventh Circuit, urging it to reject the donors' claims that the expert was unreliable.
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October 18, 2024
Tax Court Gave Short Shrift To Land Donors, 11th Circ. Told
The owners of a waterfront property in Georgia who protected 500 acres for conservation told the Eleventh Circuit that the U.S. Tax Court drastically undercut the value of their gift and its corresponding tax deduction by accepting flawed evidence provided by the government's sole witness.