On Dec. 6, 2022, the IRS issued proposed regulations identifying syndicated conservation easement transactions as listed transactions for purposes of I.R.C. § 6011. The proposed regulations are in response to a series of taxpayer victories in cases involving application of the Administrative Procedure Act (APA) to the IRS’s identification of listed transactions.
Responding to Recent Taxpayer Victories, IRS Issues Proposed Regulations Identifying Syndicated Conservation Easement Transactions as Listed Transactions
