Ottawa Silica Company (Ottawa) (plaintiff) owned a large property that could not be used for its primary business of mining silica. Ottawa wanted to sell the property to real-estate developers to be turned into a planned residential development. The local school district, Oceanside-Carlsbad Union High School District (Oceanside), identified a portion of Ottawa’s property as an ideal location for a new high school. Oceanside, a tax-exempt organization, asked Ottawa to charitably donate the parcel to Oceanside. Ottawa transferred the parcel to Oceanside and negotiated locations for Oceanside to create access roads to the high school. The value of Ottawa’s remaining property increased significantly because of the new high school and access roads built by Oceanside. Ottawa sold most of its remaining property to developers. On its federal taxes, Ottawa claimed a charitable-gift tax deduction in an amount equal to the value of the land transferred to Oceanside. The federal tax commissioner determined that Ottawa had received a substantial benefit in exchange for the transferred property, and denied Ottawa’s claim for a charitable tax deduction. Ottawa filed suit against the United States government (government) (defendant) in the United States Court of Claims for a refund. The court of claims entered judgment in favor of the government. Ottawa appealed, and the court of appeals affirmed. Ottawa appealed to the United States Court of Appeals for the Federal Circuit.