- 5 - losing land to developers and that it had a program underway to enlarge the State park system.3 In 1986, Eastleigh Development offered to purchase the same parcel of Eastleigh Farm being considered by the Commonwealth (the Property in issue). Although this second offer by Eastleigh Development was for less land than its first offer, the terms of the offer were identical to the previous offer: $10 million plus 20 percent of the profit from the development of the property. Petitioner declined Eastleigh Development's second offer as well. On May 27, 1986, petitioner granted the Commonwealth an option to buy the Property. Petitioner hired Ronald B. Handverger of Handverger & Associates of Framingham, Massachusetts, to appraise the Property. On September 30, 1986, Mr. Handverger appraised the Property at $12.5 million. On October 29, 1986, petitioner conveyed the Property to the Commonwealth. The consideration set forth in the deed for the Property was $6 million. In addition, the Commonwealth granted petitioner a Special Use Permit allowing him to harvest hay on a 22.5-acre portion of the Property for 5 years. On his 1986 Federal income tax return, petitioner valued the Property at $12 million, reporting a long-term capital gain of $5,986,499 on the sale portion of the transfer and a charitable contribution of $6 million reflecting the bargain portion of the 3The Commonwealth desired to purchase the Property and add it to the adjacent Callahan State Park.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011