The plaintiff donated a permanent conservation easement on 82 acres of Florida land. The land is presently used as a public park and conservation area, and is preserved as open space. IRS claimed that the easement was worth approximately $7 million and, as a result, the claimed $24 million deduction resulted in a 40 percent accuracy-related penalty. The IRS based it's before/after valuation on its claim that the tract should be valued in accordance with its present zoning based on prior zoning problems and likely opposition to a zoning change that would allow a higher-valued use such as multi-family housing. The plaintiff valued the before easement value of the tract based on the ability to obtain a zoning change that would allow multi-family housing on concentrated parts of the tract which left the environmentally sensitive areas as open space. The court determined that there was a reasonable possibility that the tract could be rezoned to the higher valued use, but then adjusted the plaintiff's valuation downward to reflect the downturn in the real estate market. The court determined that the easement had a value of almost $20 million, reflecting the pre-easement value of $21 million and the post-easement value of $1 million (reflecting a reduction in the property's value of slightly over 95 percent). Palmer Ranch Holdings, Ltd. v. Comr., T.C. Memo. 2014-79.