John T. Talkington and Margaret K. Talkington - Page 5

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          James Stanley Blacklock to protest the valuations placed on the             
          Litton property by the LCAD.  Mr. Blacklock, in a document                  
          presented to the LCAD on petitioners' behalf, represented that              
          all copper plumbing had been stolen from the Litton building, and           
          for all practical purposes the building was a shell.  Mr.                   
          Blacklock indicated that the best possible use for the Litton               
          building was as a warehouse which would require stripping the               
          inside.  In 1989, Mr. Blacklock estimated the value of the Litton           
          property to be $336,000.                                                    
               The LCAD determined the appraised value of the Litton                  
          property to be $499,338 as of July 19, 1990.  The LCAD determined           
          the appraised value of the Litton property to be $499,338 for the           
          years 1991 and 1992.                                                        
               On December 17, 1992, petitioners gave the 11.656 acres, the           
          parcel of 30.3 acres, and the Litton building (the gifted Litton            
          property) to the South Plains Food Bank, Inc.  Petitioners                  
          retained the 8.56 acres.  The South Plains Food Bank, Inc., is a            
          qualified charitable organization under section 170.                        
               Based on an appraisal that determined the fair market value            
          of the gifted Litton property to be $1,805,0004 on December 15,             
          1992, Mr. and Mrs. Talkington and Mr. and Mrs. Sessions deducted            
          $900,000 and $902,500, respectively, as charitable contributions            

               4  We note that both petitioners' and respondent's                     
          appraisers occasionally rounded their estimates of fair market              
          value to the nearest hundred or thousand dollars.                           




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