Ch J Patrick J. (“Scholar Pat”) Urda gets into the nitty-gritty (see p. 36) of a “shameless approach oft seen in the conservation easement oeuvre, i.e., dream up a lucrative, wholly fanciful, highest-and-best use for a property, hire a friendly appraiser willing to check his integrity at the door to provide palpably outlandish values, and entice tax-motivated investors to put money into the scheme to reap tax deductions. It does not take x-ray vision to see through this gossamer-thin stratagem.” See p. 2.

The case is Murphy Hollow, LLC, Piedmont Private Equity Manager, LLC, Tax Matters Partner, T. C. Memo. 2026-115, filed 11/5/26.

Those old, familiar faces show up yet again. The appraisers and consultants, the dodgefloggers straight from helping banks dispose of the junk they took back at foreclosures, and IRS’ experts throwing cold something-or-other on their imaginary numbers, all appear.

These boondocks are where TN meets GA, and they are real boondocks. The highest-and-best use is claimed to be high-priced residential because you can see a lake across the valley. Unfortunately, the only road to this paradise collapsed, “leading to erosion, pollution, a lawsuit by the State of Tennessee, and ultimately a court order closing the road until such time as it could be brought up to proper standards.” T. C. Memo. 2026-115, at p. 35.

The dodgefloggers, of course, claim the three-for-one writeoffs are a cinch. “Mr. Hall informed one potential client that ‘[w]e are diligent in exposing our clients to as little risk as is possible while making a meaningful difference in their tax planning,’ while telling another that ‘[g]iven all the business risks that you’ve taken in your professional life, this investment pales by comparison.’” T. C. Memo. 2026-115, at p. 17.

There so much more, but I’ll spare you.

Cain’t hardly wait for the investor class actions to begin.