Oakhill Woods, LLC v. Commissioner

In 2005, George Dixson purchased 652 acres of undeveloped land for $486,000 that was later transferred into the TOT Property Holdings, LLC (LLC). In December 2013, an investor purchased 99% of LLC shares for $1,039,000, then claimed a charitable deduction of $6.9 million on a conservation easement.

Investors purchased 143 acres on White Oak Mountain near Chattanooga, Tennessee, for $1.7 million in December 2007. Oakbrook granted a conservation easement on 106 acres a year later and claimed a $9,545,000 value for the easement — a 700% appreciation in value.

Investors purchased 143 acres on White Oak Mountain near Chattanooga, Tennessee, for $1.7 million in December 2007. Oakbrook granted a conservation easement on 106 acres a year later and claimed a $9,545,000 value for the easement — a 700% appreciation in value.

Investors purchased 143 acres on White Oak Mountain near Chattanooga, Tennessee, for $1.7 million in December 2007. Oakbrook granted a conservation easement on 106 acres a year later and claimed a $9,545,000 value for the easement — a 700% appreciation in value.