09/04/2026
A Georgia landowner claimed a $14.175 million tax deduction for a conservation easement. The Tax Court said it was worth $1 million. The Eleventh Circuit just agreed.
The case is Evans v. Commissioner. The property is Dover Hall, a 5,145-acre tract in Glynn County, Georgia, and the dispute centered on a 500-acre conservation easement. The taxpayers’ own appraisers couldn’t adequately explain how they arrived at their number, they simply stacked together flat percentage discounts. The IRS’s expert used actual comparable sales of similar timber properties instead, and the court found that far more credible.
Worth noting: the panel wasn’t unanimous. One judge dissented, arguing the majority skipped a legally required step in the analysis. Even judges don’t always agree on how to value these things, which is exactly why an independent appraisal matters so much before you’re the one defending a number in court.
This connects to something we flagged from the IRS Dirty Dozen list back in July: a real deduction holds up when you show it to a second, unrelated CPA or appraiser. If a number sounds enormous relative to what you paid in, get an independent second opinion before you file, not after the audit letter arrives.