- 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