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meeting with Mr. Krobacher, he solicited a donation from Mr.
Davis. Mr. Davis immediately committed to making a donation to
be dedicated to Dr. Sotos' research. On November 14, 1985, Mr.
Davis donated the 220 acres to the Children's Hospital
Foundation.
Mr. Garrison prepared an appraisal (the 1985 appraisal) of
the 220 acres as of May 1, 1985. Neither Mr. Davis nor his
employees provided G & K with any comparable sales information
concerning the appraisal of the 220 acres. The 1985 appraisal
concluded that the fair market value of the 220 acres was
$605,000.
On Mr. Davis' 1985 Federal income tax return (the 1985
return), Mr. Davis claimed a $605,000 charitable contribution
deduction for the donation of the 220 acres to Children's
Hospital.
The 1985 appraisal used three comparable sales to determine
the fair market value of the 220 acres. Two of the three
comparable sales never occurred.
Around 1993, Mr. Garrison first learned that two comparable
sales were nonexistent. Mr. Garrison obtained this information
from a "runner" at the Licking County Courthouse. Mr. Garrison
used the runner to obtain comparable sales because the real
property records in Licking County were not readily available.
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