The Tax Court has determined that a conservation easement for which a taxpayer claimed a $4,691,500 charitable contribution deduction over several years has no economic value and has affirmed an IRS deficiency notice and imposition of accuracy related penalties. The taxpayer owned 882 acres of largely undeveloped land in Lake County, CA, which he used for recreational use for his family. The property was largely surrounded by public lands and the only access roads were easements through neighboring lands and federal property. The federal Land Management Bureau’s easement permitted use of the ranch for single family use only. The property had a creek running through it, but a special permit...