Bloomberg Tax
June 21, 2024, 9:15 PM UTC

South Carolina Easement Lawsuit Seeks $28 Million Deduction

John Woolley
John Woolley
Reporter

A South Carolina partnership sued the IRS for denying its $28.4 million charitable contribution deduction, arguing the agency acted arbitrarily and didn’t explain why its easement conveyance couldn’t support its claimed tax benefit.

Sumter LLC asked the US Tax Court on Thursday to redetermine the IRS’s proposed adjustment, which would eliminate its deduction for the entire claimed fair market value of the conservation easement. Sumter donated its easement to Historic Columbia Foundation and deducted its alleged $28.4 million value in tax year 2015.

  • The IRS determined that Sumter failed to prove the value of its donation for the purposes of ...

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