Establishing a Conservation Easement does not require approval by the IRS. However, IRS must approve if the participants desire to take advantage of the federal tax incentives. This article takes a look at a case where after making a multi-million dollars investment and establishing a conservation easement with state and local officials only to learn after-the-fact that does not mean it will be approved by the IRS. It recommends steps golf course owners can take to ensure the successful execution of their conservation easement agreement.