"The nation behaves well if it treats the natural resources as assets which it must turn over to the next generation increased; and not impaired in value." — Theodore Roosevelt, Osawatomie, Kansas, August 31, 1910
If you invested in a conservation easement or land donation program and have received a tax notice from past years, we might be able to help.
Despite Congress creating incentives to conserve land in 1976, 2006, 2015, and 2022 through the SECURE Act, the IRS has mounted a decade-long attack on taxpayers who leveraged these incentives through investment partnerships.
Understanding Your Situation
Members and partners in these partnerships are being assessed tax on conservation-related deductions that are being eliminated and are receiving substantial tax due notices from previous years.
Many partnerships have agreed to settle long-running tax disputes with the IRS instead of facing ongoing costs and exceedingly expensive Tax Court litigation where positive outcomes are rare for all types of disputes.
In addition to the tax, a penalty is added. Both of which accrue interest from April of the year the tax is now owed.
Although it's possible to pursue this on your own, the process is layered with complexities that can easily become overwhelming. As you'll see in the Taxpayer Roadmap from the IRS, the path is anything but simple.
We see a reasonable chance of a better outcome than the partnership settlements for individuals. We've built online tools and materials with a human-staffed support team to give you the best chance at relief.
While the partnership's options are exhausted, you as an individual taxpayer retain access to IRS administrative procedures.
Challenge penalties, request interest abatement, and potentially reduce your personal tax assessment.
The IRS must still properly assess and collect from you personally—numerous ordinary procedures remain available.
What We Offer
With our expertise, we help you and your CPA avoid costly missteps and move forward with confidence.
P4C supports preserving smart, responsible incentives to encourage private land conservation.
10 years of resources and case materials, organized with AI. Research and analysis used for abatement requests are derived from these.
Enter and store your information once to complete multiple forms. Downloadable versions with plain-language guides explaining when each form applies.
Most CPAs don't deal with these types of procedures. We get them sharp fast, saving you time and money. Then we provide the solutions.
Using the library, your details and tax bills, in conjunction with the investment fund timeline, we generate your abatement request details. The most important part!
Your CPA is first, with our help. If appeals require legal expertise, we've pre-negotiated rates and expert limited support. If your CPA is not available, we can still help.
Who We Help
Whether you're an investor, CPA, or fund sponsor, we have resources tailored to your needs.
We are investors too, and see a reasonable chance of a better outcome than the partnership settlements for individuals.
While the partnership's options are exhausted, you retain access to IRS administrative procedures to challenge penalties and request interest abatement.
We've built a comprehensive set of tools with human-staffed support to give you the best chance at relief.
We work with you and your CPA to develop strategy, getting them up to speed quickly on these unique procedures.
IRS disputes can eat up time you don't have. We understand that strategies like Offer in Compromise, Collection Due Process, and Appeals are specialty services.
You already have form tools, yet this one is specific to the strategies employed—for investors and you to use repeatedly throughout the process.
No digging through IRS jargon. Step-by-step resources you can use alongside your client.
We get you smart quick on the rationale, the specifics, and the tools to help your clients with this unique set of abatement requests and appeals.
If it gets to appeals, clients can hire pre-vetted experts at a set rate who know these issues and are ready to make the case.
When the Partnership Matter has accepted a settlement and it is "final" 90 days after the order by the Judge, the tax becomes an individual taxpayer item.
In some cases the IRS is not following its manuals or steps—bypassing notices and simply mailing bills with little to no details. It's confusing, upsetting, and creating havoc with members, their accountants, investment advisors, and you.
We'll help you onboard important offering details from time of donation through finalization of settlement to enable your members to utilize this information.
10 years of organized IRS and case materials your members can lean on—all relevant to the development of these ongoing tax disputes.
Instead of everyone going it alone or giving up—working across many funds, CPAs, and thousands of investors, we can scale and automate complex yet powerful tax abatement solutions.
Tools for you to share and enable your members to understand their options. If successful, the total tax bill to post-settlement fund investors may be substantially reduced.
What You'll Receive
Here's what happens after you submit your information.
We review your tax notices, investment details, and settlement terms to understand your specific situation and identify the best strategies.
Working with you and your CPA, we develop a customized approach using interest abatement, penalty challenges, and other available procedures.
Using our AI-powered tools and 10-year research library, we generate your abatement requests, forms, and supporting documentation.
IRS Resources
The IRS Taxpayer Roadmap shows just how layered the process can be. We help you navigate it step by step.
Common Questions
Conservation easement tax disputes arise when the IRS challenges the tax deductions claimed by investors who participated in conservation easement partnerships. Despite Congress creating incentives for land conservation, the IRS has aggressively pursued these cases, resulting in many partnerships settling with significant tax assessments passed on to individual investors.
While the partnership's legal options may be exhausted, you as an individual taxpayer retain access to several IRS administrative procedures. These include requesting abatement of interest, challenging penalty assessments, and potentially reducing your personal tax liability through proper channels. These are standard, widely-used IRS procedures.
Interest often comprises up to 50% of the total amount owed. Under IRC §6404, taxpayers can request abatement of interest when the IRS has caused unreasonable delays. Given the extended timeline of many conservation easement disputes, there may be strong grounds for interest abatement requests.
Having a CPA is recommended as they serve as your primary representative. However, we can still help if your CPA is unavailable. We work to get CPAs up to speed quickly on these specialized procedures, saving both you and your CPA time and money.
The initial $3,500 covers your first tax year assessment and abatement request, including:
For multiple tax years or fund investments, expect costs to approach $7,500 for 3+ years.
If your situation requires formal appeals or legal expertise beyond what your CPA can provide, we've pre-negotiated rates with vetted tax attorneys who specialize in these exact issues. This ensures you get expert representation at a fair, predetermined rate.
Get Started
Choose your role below and fill out the form to get started.
Tell us about your situation so we can assess your options for interest abatement, penalty reduction, and potential tax relief.
Learn how we can support you and your clients through the post-settlement process with tools, consulting, and pre-negotiated legal support.
Partner with us to support your fund members. We'll help onboard your offering details and create coordinated appeals.
The IRS process is complex, but your rights are clear. Let us help you and your CPA build the strongest case possible.