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B. The Allegedly Fraudulent Items
Respondent claims that the following five items were
fraudulent:
(1) Mr. Davis' charitable contribution deduction for the
donation of the Brown Road property to the MBC in 1976;
(2) Mr. Davis' gift of Strata stock to Mr. Walker in 1984;
(3) Mr. Davis' gift of Strata stock to Dr. Ottelin in 1984;
(4) Mr. Davis' charitable contribution deduction for the
donation of the 220 acres to Children's Hospital in 1985; and
(5) Mr. Davis' charitable contribution deduction for the
donation of Strata stock to ODC in 1985.
C. General Real Estate Matters
Respondent argues that Mr. Davis' donations of the Brown
Road property and the 220 acres were part of a pattern by Mr.
Davis of donating real estate to charities, inflating the values
of the properties, and reporting the inflated values as
charitable contribution deductions on his tax returns.
Respondent alleges that Mr. Davis was able to inflate the values
of the properties he donated to charities by (1) hiring a pliable
and/or accommodating appraiser who he manipulated and (2) telling
the appraiser, in advance, the conclusions that the appraiser
should reach regarding the value of the property in question.
Respondent further contends that (1) Mr. Garrison was a
discredited appraiser and an old associate of Mr. Davis, (2) Mr.
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