Conservation Purpose, Valuation in Dispute in Easement Case

April 28, 2024

This tax refund action arises from Plaintiffs Tony and Elizabeth Townleys’ granting of three conservation easements to Oconee River Land Trust, Inc. The Townleys contend that these grants constitute charitable contributions under the Internal Revenue Code, entitling them to deductions from their taxable income for the tax years 2018, 2019, and 2020. The essence of the dispute with the IRS relates to the value of the easements and thus the amount of the deductions. The Townleys valued the easements based on the highest and best use of their property being for granite mining. The IRS maintains the easements should be valued based on comparable sales of timberland.

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