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Federal Court Upholds Land Trust Refusal to Sign Questionable Form 8283

Headlands, a real estate development company, negotiated with government regulators to develop 121 acres on the California coast. They received approval contingent on permanent protection of 29 acres of the property, and sold them to the Center for Natural Lands Management (CNLM).

When Headlands presented Form 8283 for signature, CNLM refused, and Headland filed suit. CNLM saw the sale as a permit requirement without donative intent. The court ruled in favor of CNLM citing a sales contract stating that neither party relied on tax advice from the other.

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