Tax Dispute Concerning Charitable Easements
Analysis Group was retained by the United States Department of Justice Tax Division (DOJ), defendant in a tax dispute regarding contested charitable deductions for conservation easements. Between 2003 and 2005, the plaintiff donated conservation easements on three separate plots of land, and deducted the respective values in his tax filings. The Internal Revenue Service (IRS) disputed the amounts claimed for the donations, finding them to be either nonexistent or smaller than claimed. Plaintiff alleged that the IRS audit and assessment of the values was flawed. An Analysis Group team, including Vice President David Smith and Affiliate Orlando Visbal, supported the DOJ's appraisal expert in refuting plaintiff's damages claims. At trial, the jury in the United States District Court for the District of Colorado denied plaintiff's claim for a tax refund and favorably noted the DOJ's appraisal expert's calculations in its verdict.