Document / Legal Opinion

Plateau Holdings, LLC v. Commissioner

Posted March 8, 2021 Updated August 8, 2022
Robert H. Levin
About This Legal Opinion

In December 2012, an investor acquired a 99% indirect ownership interest in 2,444 acres for $5.8 million. After donating conservation easements on all but 90 acres, a charitable deduction of $25.5 million was claimed based on before/after appraisals of $29.3 million and $3.8 million. IRS challenged.