Document / Legal Opinion

IRS Letter Ruling 201048045

Posted 2017
Author
Robert Choi
About This Legal Opinion

In this private letter ruling, the IRS denies tax exempt status to a land trust because, among other things:

1) the land trust accepted donations from a limited liability company owned and organized by a founder and officer of the land trust,

2) the land trust failed to create a baseline study or describe any particular conservation value or ecological significance,

3) no monitoring was documented and no professionals with any conservation background took part in any inspections of the land trust's properties,

4) the land trust failed to establish that the restrictions placed on the land resulted in any public benefit.

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For accreditation-related materials, please also consult the Land Trust Accreditation Commission website.