The petitioner owned land that included the habitat of the golden-cheeked warbler, and endangered bird species. The petitioner granted a conservation easement over the property to the North American Land Trust (NALT), claiming a multi-million dollar charitable deduction for the easement donation. The easement deed allowed the petitioner and NALT to change the location of the easement restriction, and the petitioners retained the right to raise livestock on the property as well as hunt the property, cut down trees, construct buildings and recreational facilities, skeet shooting stations, deer hunting stands, wildlife viewing towers, fences, ponds, roads and wells. The petitioners also sold partnership interests to unrelated parties who received homesites on adjacent land. The appraisal at issue was untimely and inaccurately described the property subject to the easement, and a NALT executive failed to clarify the inconsistencies. The court denied the charitable deduction and also imposed the additional 40 percent penalty for overvaluation (the easement was actually worth nothing). Bosque Canyon Ranch, L.P., et al. v. Comr., T.C. Memo. 2015-130.