C.C.A. 201319010 (Dec. 28, 2012)

(taxpayer's subsidiary donated land and mineral rights largely located in National Park to National Park Service and claimed charitable deduction; due to restrictions on mining in National Park, FMV of gift must be reduced by cost of removing restrictions on use and time necessary to receive removal of restrictions; if donated property only has value as mine and mining restrictions are significant, then property worthless). 

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