The Internal Revenue Service has lost on most of its arguments seeking to deny a charitable contribution deduction for the gift of a conservation easement on 622 acres of land in Liberty County, GA. But it has won the economic war when the Tax Court cut the deduction from a claimed $32.6 million to only $4.7 million after comparing the expert appraisals for each side. Seabrook Property, LLC, which had syndicated ownership in the property, claimed the deduction for the donation of the easement on property that was partially suitable for development and partially marsh land on which a state open space easement had been placed to reduce current real estate taxes. The IRS had argued that the...