Oconee landing Property, LLC v. Commissioner of Internal Revenue: Date Argued: January 28th, 2026; Docket Number: 25-10072

Case Summary: Oconee Landing Property, LLC v. Commissioner of Internal Revenue is an Eleventh Circuit appeal from a U.S. Tax Court decision disallowing most of a large charitable deduction and imposing penalties arising from a syndicated conservation easement transaction.In the Tax Court (lower court), Oconee Landing Property, LLC claimed about $20.67 million in charitable contribution deductions for donating a conservation easement over roughly 355 acres in Greene County, Georgia to a qualified land trust, but the IRS disallowed the deduction and issued penalties, and the Tax Court (Lauber, J.) held that the easement’s fair market value was under $5 million, denied most of the claimed deduction, and imposed a 40% gross valuation misstatement penalty plus a 20% accuracy‑related penalty on the remaining underpayment.The Tax Court’s memorandum opinion in T.C. Memo. 2024‑25 (and a supplemental order) concluded that the transaction was a syndicated conservation easement, rejected Oconee’s valuation and appraisal as not qualified, and found Oconee negligent in failing to substantiate its basis and obtain a compliant appraisal, ultimately directing that the decision be entered under Rule 155 after computations.Oconee Landing Property, LLC then filed a petition for review in the U.S. Court of Appeals for the Eleventh Circuit, which opened appellate case number 25‑10072 on January 8, 2025, docketed the Tax Court record in February 2025, and proceeded to full briefing, with Oconee as petitioner–appellant and the Commissioner of Internal Revenue as respondent–appellee.In the present court, the Eleventh Circuit heard oral argument on January 28, 2026, in case No. 25‑10072, where the panel questioned Oconee’s challenge to the Tax Court’s valuation and penalty findings regarding the disallowed syndicated conservation easement deduction.