Great Northern Nekoosa Corp. v. United States

38 Fed. Cl. 645 (1997)

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Great Northern Nekoosa Corp. v. United States

United States Court of Federal Claims
38 Fed. Cl. 645 (1997)

  • Written by Robert Cane, JD

Facts

The Great Northern Nekoosa Corporation and Subsidiaries (GNN) (plaintiff) owned about two million acres of timberland in northern Maine. In 1981, GNN contributed two perpetual conservation easements to the State of Maine composed of 8,000 acres of land along the Penobscot River. However, the conservation easements provided that GNN retained certain rights to extract minerals from the easement lands, including the right to extract gravel. The gravel on the land was not exposed, but rather, it was covered by soil. From at least 1986, GNN and subsequent owners of the timberlands conducted surface mining of gravel from easement lands. GNN filed a claim against the United States (defendant) for a refund of federal income taxes from the 1981 tax year. GNN claimed that it had made a charitable contribution when it granted the State of Maine the two conservation easements and was entitled to a charitable deduction. The United States filed a motion for partial summary judgment, arguing that the conservation easements conveyed by GNN were not charitable contributions under the Internal Revenue Code because GNN retained the right to extract subsurface minerals by surface mining. GNN argued that the gravel was a surface mineral.

Rule of Law

Issue

Holding and Reasoning (Horn, J.)

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