Master cartoonist Carl Rose’s immortal line about the little girl’s book report (“This book told me more about penguins than I wanted to know”) echoes in Judge Alina I. (“AIM”) Marshall’s exhaustive (and exhausting) trudge through Jackson Stone South, LLC, Jackson South Investments, LLC, Tax Matters Partner, T. C. Memo. 2025-96, filed 9/23/25.

After 146 (count ’em, 146, and I have) pages, wherein donative intent (long since demolished), appraiser qualifications (the cut isn’t hard to make), shortened holding period (new matter, which IRS stiped away), qualified appraisal (errors which IRS claims torpedo its validity notwithstanding, as these go to weight, not qualification, but watch out for those mesic hardwood forests and no, I don’t know what those are either, and oak-pine-hickory types), and the new flavor du jour comparable sales which destroy discounted cash flow, the Jacksons get the 40% gross overvaluation chop plus an evaporated deduction.

Yes, this is granular Dixieland Boondockery, with all the usual suspects among the landowner-seller (longtime Jones County real estatenik) and promoters.

But the kicker is the following, in a footnote, as usual.

“The tax opinion letters warned prospective investors: ‘PARTICIPANTS IN THE PROPOSED TRANSACTION WILL NOT BE ABLE TO RELY ON THIS OPINION TO ESTABLISH A REASONABLE BELIEF THAT THE TAX TREATMENT OF THE PROPOSED… CONSERVATION EASEMENT TRANSACTION WAS PROPER OR FOR ANY OTHER PENALTY PROTECTION PURPOSES.’” T. C. Memo. 2025-96, at p. 27, footnote 27.

Translation: “Hook up, head for the jump door, and don’t even wait for the green light.”