Carolyn Schenck Weighs in on New IRS Easement Deal in Law360

Eligible partnerships disputing conservation or historic preservation easement charitable deductions cannot negotiate their tax benefit amounts under the Internal Revenue Service's latest settlement offer, which carries a 10% penalty, the agency announced Wednesday.

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Practitioners whose clients are under audit, considering litigation or in the midst of a lawsuit "should think long and hard about passing up" the current offer, given the IRS' recent wins in several partnership easement cases in litigation, Carolyn A. Schenck of Caplin & Drysdale, a former IRS official, told Law360.

The IRS "would not be offering this kind of initiative if it didn't think that its litigation position was strong," Schenck said.

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