Charles F. and Susan G. Glass - Page 1

                                   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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