S. Robert Davis - Page 12




                                       - 12 -                                         

               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.                             







Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next

Last modified: May 25, 2011