IRS RESPONSE TO RECOMMENDATION: None given.

CORRECTIVE ACTION: N/A

TAS RESPONSE: Providing sample language for a constructive denial clause in a Chief Counsel Advice and for planning to provide more sample clauses and published guidance on conservation easements is a great start, consistent with taxpayer rights, including the rights to be informed and to pay no more than the correct amount of tax. These are encouraging developments that should help taxpayers navigate these complex issues and help prevent unnecessary litigation.

ADOPTED, PARTIALLY ADOPTED or NOT ADOPTED: Partially Adopted

OPEN or CLOSED: Closed

DUE DATE FOR ACTION (if left open): N/A