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119-hr-10510119th CongressWALLET

CERI Act of 2026

Sponsored By: Representative Bergman, Jack [R-MI-1]

Introduced

Summary

Would create a temporary Treasury settlement program to resolve disputes over syndicated conservation easement tax deductions and set clear rules for settlements, valuation, and fraud standards.

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  • Donors of syndicated conservation easements would get a clear path to settlement if their easement qualifies. Relief would depend on tests like a qualified donee, perpetual conservation, accurate qualified appraisals, and no knowing participation in fraud.
  • Donors with easements that are not "qualified" but still substantially preserve conservation purposes would receive major penalty relief. Penalties and interest would be reduced by at least 80 percent and certain penalties under sections 6662, 6662A, and 6663 would be barred.
  • The bill would pause new IRS disputes about covered transactions until the program is set up and stay pending federal court cases. It would create a rebuttable presumption that a taxpayer's qualified appraisal value is correct, treat timely Form 8886 filings as evidence of good faith, require Treasury refunds when prior payments exceed program outcomes, and require annual program reporting with National Taxpayer Advocate review for five years.

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Bill Overview

Analyzed Economic Effects

3 provisions identified: 2 benefits, 0 costs, 1 mixed.

Settlement program for conservation donors

If enacted, the Treasury would set up a Conservation Easement Resolution Program within 180 days. From enactment until it is set up, the government could not start new disputes about covered transactions and the statute of limitations would be tolled. Court cases begun before enactment could be stayed until the program decides the case. If you already paid penalties, interest, or deficiencies because of a covered transaction decided before enactment, the Treasury would pay you any excess over what the program would have required. The program would apply only to syndicated conservation easement deductions claimed for contributions made before December 30, 2022.

Fraud, disclosure, and fee protections

If enacted, the bill would raise the fraud standard so the IRS must show direct, documented proof you intentionally and willfully participated to deny relief. Filing Form 8886 for a covered transaction would be taken as proof you acted in good faith and could not be used alone as evidence of fraud. The bill would also require prevailing-party fee decisions in these disputes to be made without considering the taxpayer's net worth, which could make it easier to recover fees.

Valuation rules for conservation gifts

If enacted, a qualified appraisal you obtain would be presumed correct, and you would have the burden to rebut that presumption by clear and convincing evidence. The IRS could only challenge your value by producing its own qualified appraisal with full methodology, comparables, assumptions, and a highest-and-best-use analysis. The bill would also require appraisers to consider mineral-extraction uses when they are physically possible, legally allowed, financially feasible, and maximally productive. That mineral-use rule could raise some property values and lower some donors' deduction amounts.

Sponsors & CoSponsors

Sponsor

Bergman, Jack [R-MI-1]

MI • R

Cosponsors

There are no cosponsors for this bill.

Roll Call Votes

No roll call votes available for this bill.

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