I love reading Tax Court opinions about conservation easements because IRS always wins.  The taxpayers screw up the paperwork somehow, and the judges hold them to a strict standard.  

If you have taxable income of $2.5 million and a $2.2 million NOL, doesn't that mean you have only an AGI of $300K (assuming when you write taxable income you mean AGI, because you would not have arrived at taxable income yet without knowing the charitable deduction).  So most of the charitable contribution (conservation easement donation) is carried over to a year with higher income.  No chance to carryback that NOL under the new law?  Farmers already losing money don't have much prospect for profit in 2020.