H.R. 10510 — CERI Act of 2026

This section establishes the Conservation Easement Resolution Program within 180 days to resolve disputes over covered conservation easement deductions. It bars new IRS disputes and tolls the statute of limitations until the program begins. For qualified easements, it prohibits deficiency or penalty assessments except where the donee was unqualified, the easement was not perpetual, no qualified appraisal was attached, the taxpayer knowingly participated in fraud, or a gross valuation misstatement occurred. For non-qualified easements with substantially preserved conservation purposes, it reduces any deficiency, penalty, or interest by at least 80 percent and bars penalties under sections 6662, 6662A, and 6663. It creates a rebuttable presumption favoring the taxpayer’s qualified appraisal, requires the IRS to meet a clear-and-convincing-evidence standard with its own appraisal, stays pending court cases, refunds excess payments from prior final dispositions, awards costs without regard to net worth, and presumes good faith for taxpayers who filed Form 8886.

This section provides that a charitable contribution of a conservation easement shall not fail to qualify as exclusively for conservation purposes protected in perpetuity solely because the easement agreement addresses the treatment of post-donation improvements when calculating extinguishment proceeds. The rule applies to transactions entered into after December 31, 2009.

This section establishes a rebuttable presumption that the value of a conservation easement and the fair market value of the underlying property, as determined by a qualified appraisal obtained by the taxpayer, is accurate. The IRS must meet a clear and convincing evidence standard and produce its own qualified appraisal containing detailed methodology, comparable sales data, and all assumptions to contest the valuation. It also requires that highest and best use determinations for properties subject to qualified conservation contributions, including potential mineral extraction, mining, or oil and gas development where physically possible, legally permissible, financially feasible, and maximally productive, follow generally accepted appraisal standards.

This section requires the Secretary to submit annual reports, beginning one year after enactment and continuing for five years, to the House Ways and Means, Senate Finance, House Agriculture, and Senate Agriculture committees. Each report must detail the number of taxpayers applying for relief under the program in section 2, the number and aggregate amounts of settlements reached, the number and bases of refusals to settle, the number and aggregate amounts of payments made under section 2(e), and any recommendations for legislative or administrative changes. This section also requires the National Taxpayer Advocate to review each report and submit comments, findings, and recommendations, including on whether taxpayer rights under the Taxpayer Bill of Rights were adequately protected for qualified easements.