Legal Opinion

Stanley Works v. Commissioner

United States Tax Court

Decided August 12, 1986No. Docket No. 26475-83Published

In 1977, petitioner donated to a charitable donee a conservation easement in land adjacent to the Housatonic River in northwestern Connecticut. Petitioner deducted a charitable contribution with respect to the donation based on a value for the easement of $ 12 million. Held, the highest and best use of the land before the donation of the easement was for the construction of a hydroelectric power plant.

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In 1977, petitioner donated to a charitable donee a conservation easement in land adjacent to the Housatonic River in northwestern Connecticut. Petitioner deducted a charitable contribution with respect to the donation based on a value for the easement of $ 12 million. Held, the highest and best use of the land before the donation of the easement was for the construction of a hydroelectric power plant. Held, further, the value of the easement was $ 4,970,000. Held, further, petitioner is liable for the increased interest rate on substantial underpayments attributable to tax motivated…

1Opinion of the Court

The Stanley Works and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent

Stanley Works v. Commissioner

Docket No. 26475-83

United States Tax Court

87 T.C. 389; 1986 U.S. Tax Ct. LEXIS 65; 87 T.C. No. 22;

August 12, 1986, Filed

Decision will be entered under Rule 155.

In 1977, petitioner donated to a charitable donee a conservation easement in land adjacent to the Housatonic River in northwestern Connecticut. Petitioner deducted a charitable contribution with respect to the donation based on a value for the easement of $ 12 million. Held, the highest and best use of the land…

2Cases cited29 opinions

  1. Olson v. United StatesSupreme Court of the United States · 1934
  2. Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
  3. United States v. FisherSupreme Court of the United States · 1805
  4. United States Ex Rel. Tennessee Valley Authority v. PowelsonSupreme Court of the United States · 1943
  5. Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980

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