The CERI Act of 2026 establishes a settlement program to resolve disputes between the Internal Revenue Service and taxpayers over syndicated conservation easement deductions claimed before December 30, 2022. The IRS must create this program within 180 days of enactment and halt all new disputes related to these transactions during that period. The law significantly limits the IRS's ability to penalize taxpayers, allowing deficiencies only in cases of outright fraud, inadequate appraisals, or extreme valuation misstatements, and requiring a 180-day freeze on the statute of limitations for all related disputes. The bill also makes it easier for taxpayers to defend their valuations by creating a presumption that qualified appraisals are accurate unless the IRS provides its own detailed appraisal with clear and convincing evidence to rebut it, and it protects taxpayers who disclosed their transactions on required forms from penalties based solely on technical compliance failures. The law requires annual reports to Congress for six years detailing how many taxpayers received relief, the amounts of forgiven penalties and interest, and any cases where the IRS refused to settle.