If the title first hereinabove set forth at the head hereof (as my paid-by-the-word colleagues would say) are incomprehensible gibberish to you, just read Judge Patrick J. (“Scholar Pat”) Urda’s disquisition on kaolin mining in J L Minerals, LLC, Beasley Timber Management, LLC, Tax Matters Partner, T. C. Memo. 2024-93, filed 10/8/24.
You will learn much about the mining, processing, buying, leasing, selling, and blunging of that useful clay, the greatest source of which is found in that very same GA Dixieland Boondockery which in turn is the launchpad of “a cover to fleece the public fisc” (T. C. Memo. 2024-93, at p. 69), the Section 170(h) conservation easement.
Judge Scholar Pat notes the parties have rounded up “some of the usual suspects in this Court: (1) whether JL Minerals had donative intent; (2) whether the contribution was made “exclusively for conservation purposes,” see I.R.C. § 170(h)(1)(C), (4), (5)(A);1 and (3) whether JL Minerals obtained a qualified appraisal by a qualified appraiser, see I.R.C. § 170(f)(11)(D) and (E). Although JL Minerals scrapes by each of these requirements, we find that the deduction amount was an outrageous overstatement. Given that the value claimed on JL Minerals’s tax return ($16,745,000) exceeded the correct amount ($93,690) by more than 200%, JL Minerals is also liable for the 40% gross misstatement penalty, see I.R.C. § 6662(a) and (h).” T. C. Memo. 2024-93, at p.3.
Y’all will find Judge Scholar Pat cites all the cases I’ve blogged over the years in extenso, and then some. Out trot our old chums the willing buyer and willing seller, each armed cap-à-pié with all information and free of all compulsion, to establish that none would make a deal on the terms posited by Beasley and their cottage-industry experts.
Finally, industry experts put paid to the whole show, but Scholar Pat has to seal some of their trade secret testimony.
You will definitely learn more about kaolin than you wanted to know from this opinion, including but not in any way in limitation of the generality of the foregoing that “blunging” is the process of liquefying clay into a slurry that can by pumped through a pipeline to a processing plant.
As to farblundgeit, it is an arcane technical term meaning utterly confused, disoriented. As I was when I finished reading.
Taishoff Law 
Following received 4/23/24 from EO Tax Journal 2024-192: “Lew Taishoff has Blunging Farblundgeit, a title which he acknowledges can seem like incomprehensible gibberish. He invites you to read:
“Judge Patrick J. (“Scholar Pat”) Urda’s disquisition on kaolin mining in J L Minerals, LLC, Beasley Timber Management, LLC, Tax Matters Partner, T. C. Memo. 2024-93, filed 10/8/24. You will learn much about the mining, processing, buying, leasing, selling, and blunging of that useful clay, the greatest source of which is found in that very same GA Dixieland Boondockery which in turn is the launchpad of “a cover to fleece the public fisc” (T. C. Memo. 2024-93, at p. 69), the Section 170(h) conservation easement.”
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