Champions Retreat donated a conservation easement covering land that included a private golf course, homesites, and undeveloped areas along the Savannah River. The Internal Revenue Service disallowed the claimed charitable deduction, and the Tax Court upheld that decision. The Eleventh Circuit reversed. It held that federal tax law did not automatically disqualify an easement merely because it included a golf course. The relevant questions were whether the easement protected a relatively natural habitat or preserved open space for scenic enjoyment, and the record supported further consideration of those requirements. The court remanded for determination of the proper deduction amount. A separate opinion would have limited the holding to the scenic-open-space ground and expressed concern about whether the developed golf-course property was a relatively natural habitat.