Charles F. and Susan G. Glass - Page 38

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          special attention towards the goal of preservation and that LTC,            
          the largest membership-supported nonprofit organization in                  
          northern Michigan, has agreed through the conservation easements            
          to attempt to preserve those species by giving them that special            
          attention.                                                                  
               We apply the plain meaning of the words “habitat” and                  
          “community” to interpret them for purposes of the statute and the           
          regulations.  Cf. Venture Funding, Ltd. v. Commissioner, 110 T.C.           
          236, 241-242 (1998), affd. without published opinion 198 F.3d 248           
          (6th Cir. 1999); Trans City Life Ins. Co. v. Commissioner, 106              
          T.C. 274, 299 (1996).  A habitat denotes “The area or environment           
          where an organism or ecological community normally lives or                 
          occurs” or “The place where a person or thing is most likely to             
          be found.”  American Heritage Dictionary of the English Language            
          786 (4th ed. 2000); see also 7 C.F.R. sec. 636.3 (2002)                     
          (“Wildlife habitat means the aquatic and terrestrial environments           
          required for wildlife to complete their life cycles, including              
          air, food, cover, water, and spatial requirements.”).  A                    
          community may be defined in this context as “A group of plants              
          and animals living and interacting with one another in a specific           
          region under relatively similar environmental conditions.”                  
          American Heritage Dictionary of the English Language 374.                   
               The encumbered shoreline fits those definitions of “habitat”           
          and “community”.  In its natural undeveloped state, it is a                 






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