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Seabrook Property, LLC v. Commissioner of Internal Revenue
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August 14, 2026
11th Circ. Mulls Tax Court's Cut To $33M Easement Deduction
An Eleventh Circuit panel grappled Friday with valuation questions regarding a Georgia conservation easement, including whether the U.S. Tax Court erred in rejecting the IRS' determination while still using the agency's data points in reducing a $33 million tax deduction.
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February 26, 2026
IRS Wrongly Backs Easement Valuation, 11th Circ. Told
The IRS wrongly backed a legal error by the U.S. Tax Court in calculating the value of a Georgia conservation easement, a partnership told the Eleventh Circuit in trying to reclaim its $33 million tax deduction for the donation.
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September 26, 2025
11th Circ. Told $33M Easement Deduction Improperly Cut
The U.S. Tax Court ignored evidence of land values that the IRS had failed to rebut — or even backed — when it drastically reduced a partnership's $33 million tax deduction for donating a Georgia conservation easement, the partnership told the Eleventh Circuit.