124 T.C. No. 16
UNITED STATES TAX COURT
CHARLES F. AND SUSAN G. GLASS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17878-99. Filed May 25, 2005.
L is a longstanding nonprofit nature conservancy,
the tax-exempt purposes of which include the
preservation of wildlife, plants, and natural land on
or near the shoreline of Lake Michigan. Ps own
approximately 10 acres of land (property) that includes
a high undeveloped bluff on 460 feet of that shoreline.
Bald eagles commonly frequent the bluff. In addition,
dense vegetation grows naturally on the bluff. That
vegetation includes a species of plant, Lake Huron
tansy, that is considered to be threatened. The
natural values of the bluff also allow it to create or
promote a possible habitat for pitcher’s thistle,
another species of plant that is considered to be
threatened and that is found on the Lake Michigan
shoreline. Ps made contributions to L of two
conservation easements (conservation easements) in
perpetuity that generally preclude them or any
subsequent owner of the property from ever developing
or disturbing the natural state of much of the bluff.
Ps contributed the first easement in 1992 and the
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