Atlantic Coast Conservancy Inc.

“The conservancy provides a publication entitled "general guidelines for conservation easement projects" to all donors which details the responsibility of the conservancy in provided monitoring of the properties under conservation easement not less than annually.”

“A conservation easement ("ce") is not a marketable interest in real estate and has no segregable economic value to the conservancy. The vested property rights granted to the conservancy in the ce agreement represents an intangible asset. Under the terms of the ce agreement, the occurrence of specific conditions upon which these granted property rights may benefit the conservancy's future cash flows are considered by management as remote and unmeasurable. Therefore under generally accepted accounting principles ("gaap") a ce transaction represents neither donated assets or revenue, and thus is not recorded by the conservancy.”

“Under asc 740 "income taxes", acc assesses the likelihood, based on their technical merit, that tax positions taken in its annual informational tax return will be sustained by taxing authorities upon examination of the facts, circumstances and information available at the end of each financial statement period. Unrecognized tax benefits are measured and recorded as a liability where management has determined it to be probable a tax position would not be sustained and the amount of the unrecognized tax benefit, including associated penalties and interest, can be reasonably estimated. The amount recognized is subject to estimate and management judgment with respect to the likely outcome of each uncertain tax position. The amount that is ultimately sustained for an individual uncertain tax position, or for all uncertain tax positions in the aggregate, could differ from the amount recognized. Asc 740 is applicable to not-for-profit entities in that certain matters, such as acc's tax-exempt status, are considered tax positions taken in its annual informational tax return and thus must be assessed for potential unrecognized tax benefits. Management has determined that there is no tax liability resulting from unrecognized tax benefits relating to uncertain income tax positions taken, or expected to be taken, on its informational tax returns as of december 31, 2019. The conservancy's informational tax returns for 2014 to 2016 are currently under examinaiton by the internal revenue service. While management and the conservancy's tax counsel believe this examination will not result in unrecognized tax benefits or other adverse findings, the ultimate effects to the conservancy, if any, are unknown until such time the examination is completed.”