Judge Christian N. (“Speedy”) Weiler once again has the granite grabbing, discounted cash flow,  Dixieland Boondockery dodge on the menu in Harman Road Property, LLC, Capital Conservation Partners II, LLC, Tax Matters Partner, et al., T. C. Memo. 2026-23, filed 3/2/26. IRS, magnanimously or otherwise, folds its claim for the penalties asserted under section 6662A resulting from the identification of syndicated conservation easement transactions pursuant to I.R.S. Notice 2017-10, 2017-4 I.R.B. 544, Opinion, at p. 2, footnote 4.

It’s the usual market-rate purchase of granite-bearing land followed by selling fractional LLC interests at a 300% – 400% markup to writeoff-seeking highrollers, and claiming a conservation easement of telephone numbers featuring an appraisal by Fifth Amendment specialist CW (name omitted) and input from a bunch uomini qualificati (hi, Judge Holmes). like Qualified Persons (as defined by the SEC, the stock market guys, not the GA athletes) and Six Sigma Competent Person types.

IRS has a bunch locals from the county and a couple of taxpayer-funded qualificati of their own, including but without in any way in limitation of the foregoing their in-house appraiser Everybody Loves Raymond.

Once again its comps-vs-cash. Nobody pays the worth of the whole operation upfront, and nobody buys anything in one place when they can get it cheaper somewhere else. No need to drill and explore the comps, as everybody knows they’re in the Piedmont Fall Line where the granite is found. Comps beat cash again.

Microscopic deductions allowed. 40% gross overvaluation chops rain down.