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FUNDAMENTAL CONCEPTScharitable organizations other than schools, the court was of the view that “anybenefits to be derived from such discounts were merely incidental to the charitablenature of the transfer and, therefore, do not destroy the claimed charitablecontribution deduction.” 59 The incidental effect of this giving policy was the“development and maintenance of a favorable public image for [the company]in the eyes of those [charitable] organizations and their members.” 60In another case, a company was denied a charitable contribution deductionfor the transfer of land to a high school district, on the ground that the conveyancewas made with the expectation that, as a consequence of the constructionof public access roads through the property, it would receive substantial benefitsin return. 61 Indeed, that is what occurred. The court wrote that the “receipt orexpected receipt of substantial benefits in return for a conveyance precludes acharitable contribution [deduction].” 62 The court found that the company “knewthat the construction of a school and the attendant roads on its property wouldsubstantially benefit the surrounding land, that it made the conveyance expectingits remaining property to increase in value, and that the expected receipt ofthese benefits at least partially prompted [the company] to make the conveyance.”63 The court concluded that “this is more than adequate reason to deny[the company] a charitable contribution for its conveyance.” 64In a similar circumstance, two property owners conveyed a parcel of realestate to a corporation, taking back a note secured by a deed of trust on the property.The next year, these individuals delivered a quitclaim deed for a one-halfinterest in the note and deed of trust to a school and claimed a charitable deductionfor the value of the transfer. Two years later, as part of a settlement, the individualsassigned the note to a creditor. They advised the school of the situation,causing the school to quitclaim its interest in the note and trust to the creditor. Thenext year, these individuals made a cash payment to the school and claimed acharitable deduction for that payment. The court held that the portion of the giftof money equal to the value of the interest in the note and trust that the schoolquitclaimed to the creditor was not a gift and thus was not deductible; the excesswas found to be a charitable gift. 65 This was the outcome because, had the schoolnot executed the quitclaim, the individuals would have been obligated to pay anadditional and comparable sum of money to the creditor. “Under such circumstances,”wrote the court, “it can only be concluded that [the individuals] receiveda benefit of equal value when [the school] executed the quitclaim.” 66In another instance, an individual canceled certain property interests and apurchase option in a manner that favored a university. A charitable deductionwas claimed for the transfer of this benefit for charitable purposes. The court,however, refused to view that transaction in isolation, or as occurring in advance59 Id.60 Id.61 Ottawa Silica v. United States, 699 F.2d 1124 (Fed. Cir. 1983).62 Id. at 1135.63 Id.64 Id.65 Considine v. Commissioner, 74 T.C. 955 (1980).66 Id. at 968. 66