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Federal tax cases to watch in 2023

Law360

The legal battle rages on over a 2016 IRS notice that requires the disclosure of certain potentially abusive conservation easement deals. The IRS has now reintroduced the notice as a proposed rule with an opportunity for the public to weigh in before it gets finalized: "The IRS proposed rulemaking acknowledges the recent court decisions and looks to promulgate new rules to avoid future APA challenges and ensure consistent enforcement of the tax laws as they relate to abusive syndicated transactions," said Diana Norris, conservation defense associate director and tax manager at Land Trust Alliance. (Subscription required.)

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