- 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