Stanley Works v. Commissioner
United States Tax Court
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.
Read the full summary
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
SWIFT, Judge-.
In a statutory notice of deficiency dated June 17, 1983, respondent determined deficiencies in petitioner’s Federal corporate income tax liabilities as follows:
TYE— Deficiencies
Jan. 1, 1978. $773,642
Dec. 31, 1978 . 1,138,709
The primary issue remaining for decision is the amount petitioner is entitled to deduct with respect to a charitable contribution of a conservation easement in 668 acres of land located adjacent to the Housatonic River in northwestern Connecticut. Also at issue is whether petitioner, under section 6621(d),1 is hable for the increased rate of interest imposed…
2Cases cited28 opinions
- Olson v. United StatesSupreme Court of the United States · 1934
- Brotherhood of Railroad Trainmen v. Baltimore & Ohio RailroadSupreme Court of the United States · 1947
- United States v. FisherSupreme Court of the United States · 1805
- United States Ex Rel. Tennessee Valley Authority v. PowelsonSupreme Court of the United States · 1943
- Buffalo Tool & Die Mfg. Co. v. CommissionerUnited States Tax Court · 1980
23 more not listed; retrieve them via the Exa API.
3Cited by114 opinions
- Zirker v. CommissionerUnited States Tax Court · 1986
- Ewing v. CommissionerUnited States Tax Court · 1988
- Whitehouse Hotel Ltd. Partnership v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
- Symington v. CommissionerUnited States Tax Court · 1986
- Sealy Power, Ltd. v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
109 more not listed; retrieve them via the Exa API.