Priv. Ltr. Rul. 201222004 (Nov. 29, 2011)

(taxpayer acquired ranch for development purposes, but did not develop due to presence of two endangered species; taxpayer negotiated Mitigation Bank Agreement with government agency pursuant to which taxpayer will grant perpetual conservation easement to government in return for mitigation banking credits to allow development of other, similarly situated, land; transaction constituted sale or exchange of property under I.R.C. Sec. 1001). 

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