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The IRS Office of Chief Counsel announced in Issue Number IR-2020-130 that it will be making a time-limited settlement offer to certain taxpayers with pending docketed Tax Court cases involving such conservation easement transactions, offering finality to the affected taxpayers. The settlement offers do not address those cases that are currently pending in Examination or IRS Appeals.

Read the full GT Alert, “IRS Offers Settlement to Syndicated Conservation Easement Investors with Cases Pending in U.S. Tax Court.”

Tags: greenberg traurig, GT Insight, gt law, IRS, IRS appeals, taxpayers, U.S. Tax Court
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Photo of Barbara T. Kaplan Barbara T. Kaplan

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals…

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.

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Photo of Josh Prywes Josh Prywes

Josh Prywes focuses his practice on federal, international, multistate, and local tax planning and implementation for both U.S. and foreign companies. Josh also has experience representing investors and developers in real estate joint venture agreements and related development agreements. Josh has advised a…

Josh Prywes focuses his practice on federal, international, multistate, and local tax planning and implementation for both U.S. and foreign companies. Josh also has experience representing investors and developers in real estate joint venture agreements and related development agreements. Josh has advised a variety of businesses on the tax implications of inbound and outbound transactions. He regularly structures and negotiates complex partnership and corporate agreements throughout the United States and has experience advising clients on the tax implications of real estate transactions and corporate mergers and acquisitions.

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Photo of Michelle Ferreira Michelle Ferreira

G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California

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G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the State Board of Equalization, the Employment Development Department and county assessment appeals boards.

As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle represents clients before the IRS, and state and local tax agencies at the audit, collection, appeals and litigation stages.

Michelle has 18 reported decisions in the U.S. Tax Court on issues such as unreported income, family limited partnerships, civil and criminal tax fraud, penalty assessments, statutes of limitation assertions, valuation disputes, controversies involving valuation discounts for lack of control and lack of marketability, tax shelters, hobby losses, complex real estate transactions, tax structured transactions, and unsubstantiated business expenses.

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Photo of Scott E. Fink Scott E. Fink

Scott E. Fink focuses on civil and criminal federal and state tax controversies and litigation. He represents corporations, partnerships, estates and individuals before the Internal Revenue Service, and state and local tax authorities in examinations, collection problems, administrative appeals, and in court.

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Photo of Courtney A. Hopley Courtney A. Hopley

Courtney A. Hopley represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes.

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Courtney A. Hopley represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes. Courtney also has experience in tax planning involving entity formation, mergers and acquisitions, and reorganization transactions.

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Photo of Shira Peleg Shira Peleg

Shira Peleg is an Associate in Greenberg Traurig’s Tax Practice. She represents clients before the Internal Revenue Service and state and local taxing authorities in examinations, appeals, court, and collections.

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Photo of Jennifer A. Vincent Jennifer A. Vincent

Jennifer A. Vincent focuses on federal and state tax controversies and litigation. Ms. Vincent represents both individuals and companies in proceedings before the Internal Revenue Service and before California taxing authorities, including the Franchise Tax Board and the California Department of Tax and…

Jennifer A. Vincent focuses on federal and state tax controversies and litigation. Ms. Vincent represents both individuals and companies in proceedings before the Internal Revenue Service and before California taxing authorities, including the Franchise Tax Board and the California Department of Tax and Fee Administration. She also assists clients with compliance counseling for both federal and state-based tax issues.

Ms. Vincent has considerable experience in defending clients in federal offshore audits and income tax examinations and in California income, sales and use tax, and property tax matters.

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