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GREAT NORTHERN NEKOOSA CORP. v. UNITED STATES

No. 82-1751.

711 F.2d 473 (1983)

GREAT NORTHERN NEKOOSA CORPORATION, Plaintiff, Appellant, v. UNITED STATES of America, Defendant, Appellee.

United States Court of Appeals, First Circuit.

Decided July 18, 1983.

Rehearing and Rehearing Denied September 9, 1983.

Attorney(s) appearing for the Case

Mark A. Michelson, Boston, Mass., with whom Mitchell H. Kaplan, and Choate, Hall & Stewart, Boston, Mass., were on brief, for plaintiff, appellant.

Richard Farber, Atty., Tax Div., Dept. of Justice, Washington, D.C., with whom Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Atty., Tax Div., Dept. of Justice, Washington, D.C., and Richard S. Cohen, U.S. Atty., Portland, Maine, were on brief, for defendant, appellee.

Before BOWNES and BREYER, Circuit Judges, and WYZANSKI, Senior District Judge.

Rehearing and Rehearing En Banc Denied September 9, 1983.

WYZANSKI, Senior District Judge.

The question presented is the amount deductible from gross taxable income on account of a parcel of real property donated by the taxpayer, Great Northern Nekoosa Corporation, to the State of Maine for charitable purposes, pursuant to the deduction allowance authorized by § 170(c)(1) of the Internal Revenue Code of 1954, 26 U.S.C. § 170(c)(1) (1976)....

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