A federal appellate court decided the IRS undervalued a wealthy landowner’s donation of 82 acres to Sarasota County for a park.

The property has hosted two bald eagles and their nest, a fact not lost on the judge who wrote the opinion in Palmer Ranch v. IRS. U.S. Court of International Trade Judge Richard W. Goldberg brought tax acumen and wit to his stint on the U.S. Court of Appeals for the Eleventh Circuit.