Judge Christian N. (“Speedy”) Weiler looks to the somewhat controversial opinion of Judge Courtney D (“CD”) Jones in Valley Park Ranch (for which see my blogpost “‘Highly Contestable’ Gets Brushhogged,” 3/28/24), and lets Green Valley Invs., LLC, Docket No. 17379-19, filed 4/8/25, claim a deduction for a qualified charitable easement for year at issue. The Proceeds Regulation is indeed in violation of the APA.

As for the amount of said deduction, Judge Speedy Weiler sticks by his valuation numbers when he computed the penalties.

IRS’ claim that the Green Valleys and their appraisers colluded, thereby disqualifying their appraisal, fares no better. “We acknowledge there was a prior appraisal performed on the 607-acre parcel before it was subdivided into four smaller parcels, and the values for each parcel remained essentially the same, after subdivision. However, we cannot conclude that this fact establishes collusion between these parties. We have previously considered, and rejected, respondent’s argument in our Memorandum Findings of Fact and Opinion.” Order, at p. 4.