Shelby County, AL, is just awash with limestone, and highrollers looking for write-offs hastened to join in. Only instead of quarrying, they bought into SCEs. Judge Albert G. (“Scholar Al”) has a full-dress T. C. deconstructing valuation.

The bottom line is that no one pays the entire worth of a going business for a place to put it, when they still have to pay start-up and development costs to get it going.

Ranch Springs, LLC, Ranch Springs Investors, LLC, Tax Matters Partner, 164 T. C. 6, filed 3/31/25, boils down to two propositions.

“No rational buyer with knowledge of all relevant facts would pay, for one asset needed to operate a business, the entire future value of the business.” 164 T. C. 6, at p. 3.

“At the end of the day, petitioner’s position appears to rest on its assertion that the ‘willing buyer/willing seller’ test, which governs the valuation of property for charitable contribution purposes generally, does not apply when the donated property is a conservation easement. Petitioner cites no judicial precedent or other authority to support this novel proposition. There is none.” 164 T. C. 6, at pp. 62-63.

Once again, we have the classic Dixieland Boondockery. “The value Ranch Springs claimed for the easement on its [year at issue] return was $25,814,000. We have determined that the value of the easement on the valuation date was only $335,500. The claimed value thus exceeded the correct value by $25,478,500 or 7,694%. The valuation misstatement was thus ‘gross.’” 164 T. C. 6, at p. 65.