Tyler Arnold has published Note, Double Eagle: Internal Revenue Code Section 170(h), 15 Se. Envtl. L.J. 457 (2007). Here is part of the Introduction:

During a time period of increased scrutiny of conservation easements and frequent demands for an absolute ban of conservation easements on golf courses, the purpose of this note is not to argue in favor of blanket or widespread granting of tax deductions for all owners of golf courses donating easements on various fairways and sand traps. Conversely, this note supports the minority of golf courses owners who, just like private landowners, aspire to contribute to the preservation of the environment. This note further recognizes exactly how golf course conservation easements can comply with the mandatory conservation purposes test under the IRC. After reviewing the statutory and regulatory requirements for creating a qualified conservation contribution, this paper reviews the criticisms of golf course conservation easements, and discusses the recent precedent set in the Glass v. Commissioner of Internal Revenue decision regarding the conservation purposes test. The court’s analysis in Glass is then examined for potential guidance to golf courses seeking to implement conservation easements, and other means by which golf courses may satisfy the statute and successfully donate qualified conservation easements. Finally, the paper makes some recommendations and concludes golf courses can be the double eagle of § 170(h).