The Tax Court, on remand from the 11th Circuit, which decided that the taxpayer was entitled to a charitable donation for donation of a conservation easement, now valued that interest to determine the amount of the donation deduction. Both parties presented valuation opinions from expert appraisers. The Tax Court determined that the highest and best use of the property before and after the grant of the easement was the key to the determination of the value of the easement. The Tax Court then analyzed the evidence from the expert appraisals to arrive at a value of the easement.