John T. Talkington and Margaret K. Talkington - Page 7

                                        - 7 -                                         

               The Bates Center building was primarily a gymnasium with a             
          full length basketball court, but it also contained some small              
          classrooms, a storage area, a parlor, a small kitchen, locker               
          rooms, rest rooms, and a small fireplace.  The Bates Center could           
          be used as a church.                                                        
               On June 7, 1991, Mr. Sessions acquired the Bates Center and            
          the adjoining church (located directly to the east of the Bates             
          Center) in a trade with the First Church of the Nazarene.  The              
          traded properties were each valued at $600,000.  Mr. Sessions               
          owned the entire fee simple interest in the Bates Center.                   
               On September 23, 1992, Mr. Sessions gave the Bates Center to           
          the Northwest Texas Church of God in Christ.  The Northwest Texas           
          Church of God in Christ purchased the church that adjoins the               
          Bates Center for $550,000.6  The Northwest Texas Church of God in           
          Christ is a qualified charitable organization under section 170.            
               Based on an appraisal that determined the fair market value            
          of the Bates Center to be $350,000 on December 23, 1992, Mr. and            
          Mrs. Sessions deducted $350,000 as a charitable contribution on             
          their 1992 Federal income tax return for the gift of the Bates              
          Center.                                                                     
               Respondent determined that the market value of the Bates               
          Center on September 23, 1992, was $178,000.                                 

               6  Although it is unclear from the record, it appears that             
          the gift of the Bates Center and the purchase of the adjoining              
          church occurred relatively close in time to one another.                    




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011