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Relief on an LCE case is not necessarily all or nothing.Depending on the specific facts, there can be a genuine basis to...
08/25/2026

Relief on an LCE case is not necessarily all or nothing.

Depending on the specific facts, there can be a genuine basis to dispute the disallowance itself, particularly where the appraisal methodology or the conservation purpose can be defended on the merits. Separately, even where the underlying tax on a disallowed deduction is ultimately owed, there can still be room to address the penalties and interest attached to it through a distinct process.

It is also worth understanding that liability can extend to a joint filing spouse, and that it does not matter who originally structured or promoted the deal. Those two points tend to surprise people who assume their exposure ended when the partnership itself dissolved or stopped operating.

08/24/2026

Can the IRS really take my paycheck? Do you qualify for a settlement? Is it too late to fix this?

These are the questions we hear most, so we built a new page just for that.

Honest, bite sized answers before you ever have to book a call. No pressure, no sales pitch, just a place to get your bearings.

Start here: link in bio.

Ready to talk through your specific situation?

Grab a spot on my calendar at goldenliontax.com.

Responding to an LCE examination generally involves a close review of several distinct pieces of the original transactio...
08/24/2026

Responding to an LCE examination generally involves a close review of several distinct pieces of the original transaction.

That includes the appraisal itself and the methodology behind it, the conservation purpose documentation that established why the easement qualified for a deduction under the relevant code section, and the structure of the partnership or syndication that facilitated the deal. Each of these pieces can independently strengthen or weaken a position once the IRS begins asking detailed questions, which is why a thorough response typically cannot rely on any single document alone.

Because these cases often involve records that are several years old by the time an examination begins, locating and organizing this material early tends to make a meaningful difference in how the process unfolds.

08/24/2026

A payment plan isn’t automatically a fix.

If it doesn’t fit your real financial picture, it just delays the pressure instead of solving the problem.

Before you agree to anything with the IRS or state, ask yourself if it’s actually sustainable long term, not just whether they’ll accept it.

Take the free quiz at GoldenLionTax.com to find out where you stand.

When the IRS disallows an LCE deduction, the financial exposure is not limited to giving back the deduction itself.Inter...
08/21/2026

When the IRS disallows an LCE deduction, the financial exposure is not limited to giving back the deduction itself.

Interest accrues from the original filing date of the return that claimed the deduction, which means the longer a case takes to work through examination and appeals, the larger that interest component becomes. On top of that, accuracy related penalties, and in some cases more significant penalties tied to gross valuation misstatements, can apply depending on how far the underlying appraisal is found to have overstated the value of the easement.

Taken together, these components are why the total amount ultimately at stake in an LCE case is often substantially larger than the deduction that was originally claimed.

Syndicated conservation easements involve a group of investors pooling money into a partnership that then claims a singl...
08/20/2026

Syndicated conservation easements involve a group of investors pooling money into a partnership that then claims a single, shared deduction tied to the easement.

The IRS has treated many of these arrangements as listed transactions, a designation reserved for structures the agency considers to carry a high risk of abuse. That designation triggers additional disclosure requirements for participants and materially increases the likelihood that any individual return connected to the deal will be selected for examination, regardless of how the specific investor's return was otherwise prepared.

For anyone who invested in one of these partnerships, it is worth understanding that the scrutiny is often directed first at the structure and appraisal behind the deal itself, and only afterward at the individual returns that claimed a share of the resulting deduction.

A land conservation easement deduction is based on the appraised value of the development rights a landowner permanently...
08/19/2026

A land conservation easement deduction is based on the appraised value of the development rights a landowner permanently gives up when the easement is placed on the property.

That valuation is exactly where the IRS concentrates its scrutiny. Because the deduction depends on an appraisal rather than a fixed transaction price, there is inherently more room for disagreement over what those development rights were actually worth at the time the easement was granted. An aggressive or unsupported appraisal can turn what looks like a straightforward charitable contribution into a multi year examination.

Understanding that the appraisal sits at the center of these cases helps explain why LCE audits tend to be far more document intensive than most other individual or business examinations.

IRS examination activity around worker classification has been picking back up, and it is expected to remain an area of ...
08/18/2026

IRS examination activity around worker classification has been picking back up, and it is expected to remain an area of focus over the coming year.

Part of the reason is straightforward. Worker classification directly affects payroll tax revenue, since it shifts responsibility for withholding away from the business and onto the individual. That makes it a consistent enforcement priority across changing IRS staffing and budget levels, since the rules themselves have not changed even as attention to enforcing them has increased.

For business owners, this trend is less about a new rule to learn and more about renewed enforcement of standards that have existed for years. Reviewing how contractor relationships are structured now is a very different exercise than trying to reconstruct that reasoning during an active audit.

There is a narrow form of protection available in some worker classification cases, known as the Section 530 safe harbor...
08/17/2026

There is a narrow form of protection available in some worker classification cases, known as the Section 530 safe harbor.

To qualify, a business generally needs to demonstrate a reasonable basis for treating a worker as a contractor, such as relying on long standing industry practice, a prior IRS audit that did not raise the issue, or guidance from a professional advisor. The business also needs to show consistency, meaning it treated similarly situated workers the same way and filed the appropriate 1099 forms for all of them, not just some.

This protection is not automatic and does not retroactively fix inconsistent treatment. It depends heavily on documentation that was created and maintained before an audit ever began, which is why reviewing classification practices proactively matters more than trying to justify them after the fact.



When a worker is reclassified from independent contractor to employee, the financial impact extends beyond a single tax ...
08/14/2026

When a worker is reclassified from independent contractor to employee, the financial impact extends beyond a single tax return.

Payroll taxes come into play first, since employers are generally responsible for the portion of Social Security and Medicare taxes that would have been withheld and matched under an employment relationship.

Unemployment insurance contributions and workers compensation coverage can also apply retroactively, since both are tied directly to how the worker was classified during the period in question.

Each of these obligations is calculated separately, which means they can stack rather than offset one another.

Because a classification review can look back across multiple tax years, a single misclassified role can turn into a liability that is considerably larger than it would appear looking at any one year in isolation.

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Ogden, UT

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