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          nonexistent comparable sales until many years after Mr. Garrison            
          prepared the 1985 appraisal and Mr. Davis deducted the donation.            
          We conclude that Mr. Garrison's use of the nonexistent comparable           
          sales does not establish fraud on the part of Mr. Davis.                    
               Respondent also implies that Mr. Davis improperly "bought"             
          Dr. Sotos' testimony in the Squirrel Bend litigation via the                
          donation of the 220 acres to Children's Hospital.                           
               In the Squirrel Bend litigation, Dr. Sotos testified to the            
          grand jury and at the trial; however, Mr. Davis agreed to make              
          the donation to Children's Hospital long before he was indicted             
          in, or Dr. Sotos became aware of, the Squirrel Bend litigation.             
          Furthermore, Dr. Sotos credibly testified the his integrity was             
          not for sale.                                                               
               We conclude that Mr. Davis' donation of the 220 acres to               
          Children's Hospital was for charitable purposes and was not an              
          attempt to influence Dr. Sotos' testimony in the Squirrel Bend              
          litigation.                                                                 
               Respondent also asserts that the 1985 return was fraudulent            
          because on Form 8283, filed as part of the 1985 return, the basis           
          of the 220 acres was left blank.                                            
               Mr. Stimmel testified that not completing the entry on Form            
          8283 under donor's cost or adjusted basis was an oversight and              
          that any blanks were his actions.  See also infra (regarding Mr.            
          Davis' reliance on return preparers).  He further testified that            
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