Tax 625 Research Paper Your new client is an investor in a syndicated conservation easement. The related charitablecontribution deduction claimed on the individual 1040 was entirely disallowed following the IRSsexamination of the tax return. The case is currently pending in Tax Court. The client has learned the IRS has offered to settle these cases. The offer follows a string of IRSvictories over investors and the related partnerships formed to purchase property for thepurpose of donating a conservation easement to an exempt organization. The IRS considersthese abusive transactions.Prepare a memo that (1) briefly discusses the rules governing charitable deductions forconservation easements. Your memo must (2) discuss at least 3 recent court cases where theIRS has challenged those deductions in court. Take note: a number of the recent IRS victoriesin the SCE cases are currently on appeal (and may, perhaps, be reversed).After your review of the applicable cases and authorities, (3) summarize the advantages anddisadvantages of the IRS settlement offer.Finally, (4) do you recommend that the client accept the settlement or continue to challenge thedisallowance (even if it requires litigation). You should justify whichever option you advise yourclient to undertake. In writing up your memo please address points 1-4 highlighted above. You must rely on and cite primary sources for your positions. The final product should be roughly 6-8 pages in length, exclusive of the footnotes & citations.
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