This scheme is likely one of many that Trump has used to reduce his tax bill - inflating the value of the conservation easement would allow him to overvalue the charitable gift (which offsets his tax liability). He didn't actually have to pay $21M or get a refund for it, he reduced his tax bill via the charitable gift.
This is fairly pedestrian stuff though. Trump and his family have done far worse, e.g. funneling money from the Trump Foundation (his "charity" that is now closed) into Trump's businesses

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