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Palmer Ranch Holdings, Ltd., et al.v.Commissioner of Internal Revenue

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.14-14167
DecidedFebruary 5, 2016
Reporter812 F.3d 982
JudgesCircuit Judges Rosenbaum and Julie Carnes, and Judge Richard W. Goldberg of the U.S. Court of International Trade sitting by designation; Goldberg authored
Tags
CivilTax LawBusiness LawProperty LawStatutory InterpretationDamagesReversalRemand
Case Summary

Palmer Ranch challenged the Tax Court’s valuation of B-10, property burdened by a donated conservation easement. The Eleventh Circuit affirmed the finding that the parcel’s highest and best use was residential development at moderate density, but reversed its $21,005,278 valuation because the appreciation rate and calculations lacked adequate support in the evidentiary record. On remand, the Tax Court must use its comparable-sales analysis or explain a different method, ground the appreciation rate in the evidence, and calculate the value correctly; any quantitative adjustment must account for qualitative adjustments already made. The court allowed a lower valuation if supported by the evidence.

Opinion

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