Attorneys defending taxpayers against the IRS
Examinations, IRS Appeals, Tax Court proceedings, refund matters, valuation disputes, penalties, and related controversy.
Discuss your matterConservation Easement valuation intelligence
Vestal Analytics assists Partnerships, Attorneys, CPAs, Promoters/Sponsors, Appraisers, Technical experts, and Investors/Taxpayers to examine the IRS’s valuation process, organize the property record, and determine what the available facts actually support.
Comparative intelligence developed from the Vestal Analytics Valuation Database using IRS Conservation Easement valuation reports spanning six years and growing.
IRS Conservation Easement valuation reports in the Vestal Analytics database
Data is organized around the actual property allegations and hazards of litigation
The Strength Index assesses each data source separately on a 0-to-5 scale
Having direct access to our team in a timely fashion matters.
Where the analysis begins
Many Conservation Easement disputes turn on two separate but connected questions:
We review the process, qualifications, fieldwork, source documentation, certifications, assumptions, and treatment of property-specific facts, then compare the findings with patterns across our database.
We organize offering materials, private placement memoranda, subscription documents, risk disclosures, ballots, yield illustrations, communications, and professional-adviser involvement to create a traceable transaction record.
The Vestal Analytics difference
An Attorney can research the law and analyze the pleadings. Vestal Analytics adds a comparative data analytics capability developed from our IRS Conservation Easement Valuations database and applies that intelligence to the specific property, valuation, allegations, disclosures, and participant record.
Who we serve
Vestal Analytics serves attorneys handling IRS disputes, attorneys defending easement professionals, litigants facing investor claims, and individual investors working with their professional advisers.
Examinations, IRS Appeals, Tax Court proceedings, refund matters, valuation disputes, penalties, and related controversy.
Discuss your matterCounsel representing sponsors, promoters, developers, partnership representatives, appraisers, geologists, accountants, attorneys, engineers, and other transaction participants.
Discuss your matterTransaction participants organizing the factual record and examining whether allegations or claimed damages depend on an IRS valuation or an incomplete record.
Discuss your matterInvestors and their advisers seeking a clearer understanding of the documented record and the questions that remain unresolved.
Discuss your matterWhat we do
An engagement brings the valuation, transaction documents, allegations, professional work, communications, and comparative data into one controlled analytical record. The scope is tailored to the property and litigation needs.
Strength Index
The Vestal Analytics Strength Index converts a large and often fragmented record into a disciplined comparison of the facts available to each viewpoint. Each defined category is scored from 0 to 5 and multiplied by its approved weight.
The defense score and opposing-party score are calculated independently. They do not have to total 5. Both positions may be strong, both may be weak, or the record may remain incomplete.
Scores are calculated independently and do not have to total 5. The Index responds to facts rather than advocacy; unknown facts are shown, not silently treated as favorable.
About Vestal Analytics
Vestal Analytics began with a striking valuation disparity: a taxpayer valued a Conservation Easement at $70 million, while the IRS appraisal placed its value at $130,000. A second easement showed a 99.5% reduction, and ten more IRS valuations followed the same pattern. That pattern prompted a broader inquiry into the evidence, qualifications, assumptions, and methods behind the valuations.
Today the firm maintains a proprietary research database of more than 225 IRS Conservation Easement valuations, led by founder and Chief Executive Officer Bernie Donachie, a process-review and comparative-analytics consultant with more than 40 years of experience.
Featured reporting and insights
Selected observations concerning IRS valuation processes, report characteristics, technical-review practices, comparative patterns, and data organization—plus national reporting that has drawn on Vestal Analytics research.
A review of more than 200 IRS Conservation Easement valuations, representing more than $5 billion in taxpayer-claimed values, found recurring errors that favor the same side. With potentially billions at stake, taxpayers deserve IRS valuations that are accurate and independently supported.
Read the insightJust the News · Ashe Short
Just the News reports on an independent review of more than 130 IRS Conservation Easement valuations that found reductions of roughly 97% from taxpayers’ expert appraisals, with 62.4% of the reviewed valuations performed as desk reviews and few identifying a technical specialist with a recognized professional qualification.
Read at Just the NewsAn IRS Report of Value typically names the standards, scope, sources, and certifications behind its conclusion. Reading those statements as testable claims—rather than boilerplate—is the first step in a property-specific review.
Read the insightTestimonials
Perspectives from people who have seen Vestal Analytics research and process review firsthand. Read all testimonials on What Others Say →
I have been incredibly impressed with Vestal Analytics. As an attorney, I spend a great deal of time digging into facts and looking for the details that can make a difference in a case. Vestal Analytics takes that process to another level. Their ability to dig deeply into large amounts of data, identify patterns, and uncover important information that might otherwise be missed is remarkable. Their work has helped me identify facts that have been genuinely valuable to my cases.
As a sponsor and managing partner of conservation easement partnerships, I have dealt extensively with the complexities of IRS valuation disputes. I have engaged Vestal Analytics to conduct detailed reviews of multiple IRS appraisal reports and assist in preparing for IRS Appeals hearings.
The depth and thoroughness of their research has been extraordinary. Vestal Analytics has identified significant deficiencies, inconsistencies, and methodological concerns in IRS valuations that had previously gone unrecognized, despite extensive professional review.
What distinguishes Vestal Analytics is its ability to combine meticulous investigative research with comprehensive comparative data and process analysis. Their findings have provided our legal team with important new evidence and a stronger foundation for challenging IRS valuation conclusions.
As a result of Vestal Analytics’ work, the IRS is now being asked to explain and substantiate valuation conclusions that previously went largely unquestioned.
For sponsors, managing partners, attorneys, and taxpayers facing complex IRS valuation disputes, I consider Vestal Analytics an exceptionally valuable resource.
I have had the pleasure of working with Bernie Donachie on several projects over the past six months and have developed a tremendous appreciation for his exceptional analytical abilities, investigative discipline, and approach to complex problem-solving.
What distinguishes Bernie, and what he brings to Vestal Analytics, is his remarkable ability to identify issues, inconsistencies, and underlying problems that even highly qualified professionals may overlook. He approaches every assignment with uncommon curiosity, logical reasoning, and an unwavering commitment to understanding the facts.
Drawing on a distinguished consulting career with organizations including IBM and Accenture, Bernie has developed an approach that combines detailed research, disciplined analysis, and the ability to communicate complex findings in a clear, concise, and compelling manner.
Vestal Analytics reflects these strengths by bringing independent thinking, investigative rigor, and evidence-based analysis to complex valuation and process issues.
Having worked directly with Bernie and experienced the quality and thoroughness of his work, I highly recommend Vestal Analytics to professionals and organizations seeking a deeper understanding of complicated issues and the evidence underlying them.
Vestal Analytics LLC. has produced one of the most important independent analyses of the federal government’s conservation easement valuation practices that I have seen.
By examining IRS appraisal reviews, Vestal Analytics identified a remarkable pattern of valuation reductions and documented serious questions about the methods used to reach those conclusions. Their work demonstrates why rigorous, property-specific analysis matters and why conclusions should never be accepted without examining the underlying evidence.
This is precisely the kind of independent thinking, technical competence, and professional diligence the conservation easement industry needs. I would strongly encourage anyone facing a complex conservation easement valuation question to consider Vestal Analytics’ expertise.
As a participant in a conservation easement, I have been extremely impressed by the depth, thoroughness, and professionalism of the research and analytics conducted by Vestal Analytics. Their ability to examine complex IRS valuation reports, identify inconsistencies, and uncover patterns across hundreds of valuations is extraordinary.
What impressed me most is that their findings are supported by detailed, documented evidence—not speculation or opinion. Vestal Analytics has brought a level of transparency, insight, and accountability to this process that I had not previously experienced. Their work has fundamentally changed my understanding of how these valuations are conducted and has given me greater confidence in the importance of challenging unsupported conclusions. This is the kind of independent, fact-based analysis that taxpayers deserve.
I have known Bernie Donachie for years and worked alongside him through a complex conservation easement valuation dispute with the IRS. That experience has given me firsthand appreciation for his exceptional investigative ability, analytical rigor, and determination to uncover the facts.
What distinguishes Bernie is his ability to dig deeper when others have stopped looking. He methodically examines documentation, challenges assumptions, connects seemingly unrelated details, and identifies important issues that even experienced professionals may have overlooked.
In our own experience, his research uncovered significant questions that had not previously been adequately explored. He doesn’t simply accept conclusions; he wants to understand how they were reached and whether the evidence supports them.
Vestal Analytics is a natural extension of these extraordinary strengths. Bernie brings investigative persistence, process expertise, and analytical discipline to some of the most complex valuation disputes. His work provides a perspective that is both distinctive and invaluable.
If you are counsel, a transaction professional, or a person or firm facing an investor claim, or even an investor seeking a clearer understanding of the documented record, contact Vestal Analytics for a confidential introductory conversation.