Allen M. Glick - Page 5

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          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.                                     




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