Katherine Strasburg - Page 5




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               The easement gifts in 1993 and 1994 were legally valid in              
          accordance with the terms thereof and are binding on petitioner             
          and "all future owners and tenants".  Petitioner did not receive            
          consideration from MLR for the easement gifts.                              
               During all relevant periods, MLR was an organization                   
          described in section 501(c)(3), and donations of qualified                  
          conservation easements to it are deductible under section 170(h).           
          The MLR easement executed by petitioner on September 9, 1993, and           
          recorded on September 13, 1993, is a "qualified conservation                
          contribution" under section 170(f)(3)(B)(iii) and (h).  In                  
          addition, the amendment executed in favor of MLR by petitioner on           
          November 17, 1994, and recorded on November 29, 1994, is a                  
          "qualified conservation contribution" under section                         
          170(f)(3)(B)(iii) and (h).                                                  
               Petitioner's property is a spectacular piece of property               
          surrounded by the Gallatin National Forest on three sides.                  
          Properties surrounded by nondeeded National Parks are known as              
          inholdings.  Petitioner's property is properly classified as an             
          inholding.                                                                  
               Petitioner's property is approximately 320 acres in size and           
          is situated on the floor of the Boulder River Valley.  It is                
          irregular in shape and ranges from gently to moderately sloping             
          native rangeland and timber-covered land.  The Boulder River, a             








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