The Internal Revenue Service announced the establishment of an Office of Conservation Easements and ended its uniform settlement initiative for those cases, effective immediately.
The agency said that experience administering the initiative has shown that standardized settlement offers on a rolling basis are not suited to the full range of conservation easement cases, which may have different partnership agreements, insurance arrangements, and procedural situations that affect when and how taxpayers evaluate settlement.
The Office of Conservation Easements will centralize technical expertise and coordinate policy, enforcement, and case-resolution strategy across the IRS and with the Office of Chief Counsel. It will also support engagement with taxpayers, practitioners, and conservation and historic preservation organizations.
The IRS will not issue any additional uniform settlement letters under the May 13 program, and any deadlines for accepting previously issued offers are withdrawn. Prior elections to participate in the settlement framework remain in effect and will be processed according to their terms. Taxpayers with pending cases may continue to request settlement under the May 13 framework through their assigned IRS representative. Individual cases may continue to be resolved on different terms where warranted by litigation risk.