Savannah Shoals donated a conservation easement over 103 acres and claimed a $23 million charitable deduction. The Tax Court found that an aggregate quarry was not a financially feasible highest-and-best use and valued the land at $480,000 instead, leading to tax consequences and penalties. The Eleventh Circuit held that the Tax Court used the correct legal framework and did not clearly err in relying on market demand and competition; it affirmed the judgment.