Battle of the Experts: $2.9M vs. $30M in Minerals
The IRS introduced an additional expert specializing in mining and engineering, who estimated the land’s mineral value at $2.9 million. However, he dismissed the feasibility of a quarry, arguing that high start-up costs would prevent any reasonable return on investment.
By contrast, Savannah Shoals’ own experts insisted a quarry was viable, with one valuing the land’s minerals at $30 million—a dramatic difference that highlights the case’s complexities.
What’s Next?
The Eleventh Circuit will now decide whether to uphold the Tax Court’s ruling, a decision that could set a significant precedent for conservation easement tax deductions.
Savannah Shoals’ attorneys did not immediately respond to requests for comment. The U.S. Department of Justice, Tax Division, declined to comment.
Legal Teams
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Savannah Shoals is represented by:
- Jerrika C. Anderson
- John W. Hackney
- Alan M. Shapiro of Chamberlain Hrdlicka White Williams & Aughtry
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The U.S. government is represented by: