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Abstract: 

In the recently decided case, Salt Point Timber, LLC v. Commissioner, the Tax Court was tasked with interpreting the effectiveness of contract language contained in the grant of a conservation easement. At no point did the IRS question the appraised value of the Property, the amount of the deduction, or the motives behind the conveyance. Nevertheless, the IRS disallowed the deduction in its entirety. While the court ultimately reached a questionable result, the opinion nevertheless constitutes a cautionary tale for practitioners.

Keywords: Salt Point Timber, LLC; Lord Berkeley Conservation Trust; IRC §170(h)(1); comparable conservation easements

Affiliations:  1: Strasburger & Price, LLP.