Georgia landowner's $23 million tax claim over 103 acres cut to $480,000 by court

The company said the land could be used as an aggregate quarry before the easement. (Representational AI photo) A Georgia landowner claimed a $23 million charitable tax deduction after donating a conservation easement over 103 acres of land. The valuation was based on the argument that the property’s 'highest and best use' before the easement was as an aggregate quarry. A US appeals court upheld a much lower valuation of $480,000 and a 40% gross valuation misstatement penalty.The case involves Savannah Shoals, LLC, which donated the conservation easement in 2017 on a 103-acre property in Hart County, Georgia, Reuters reported. On its tax return, the company claimed a $23 million charitable contribution deduction under Section 170 of the Internal Revenue Code.The company’s valuation depended on the proposed quarry use. It argued that the land could be used as an aggregate quarry before the conservation easement was placed on it. The Internal Revenue Service rejected the deduction and also imposed a 40% gross valuation misstatement penalty.Savannah Shoals challenged the IRS decision in the US Tax Court. But the Tax Court agreed with the IRS that the proposed quarry was not the proper...