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Mr. Davis did not condition his gift of the Brown Road
property to the MBC on the MBC's granting to Mr. Eddy or Ms.
Mascari a tuition waiver. Pastor Brock never discussed this
issue with Mr. Davis.
Mr. Garrison prepared an appraisal of the Brown Road
property as of December 20, 1976. Mr. Davis and Mr. Garrison had
no conversations regarding the Brown Road property. Neither Mr.
Davis nor his employees provided G & K with any comparable sales
information concerning the appraisal of the Brown Road property.
The appraisal concluded that the Brown Road property's fair
market value was $400,000.
On Mr. Davis' 1976 Federal income tax return (the 1976
return), Mr. Davis claimed a charitable contribution deduction in
the amount of $400,000 in connection with his donation of the
Brown Road property to the MBC. The donation of the Brown Road
property was reported and identified on Schedule A of the 1976
return. Two additional pages concerning the donation also were
attached to the 1976 return: (1) An acknowledgment letter from
Pastor Brock and (2) a letter from G & K opining that the fair
market value of the Brown Road property as of December 20, 1976,
was $400,000. The G & K opinion letter made explicit reference
to the contemporaneous appraisal report that detailed the
valuation methodology, but it was not attached.
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