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(Malina) prepared a document valuing the religious articles for
petitioner. Malina, however, provided no methodology or
rationale for the values at which he arrived.
Walzer provided to petitioner letters dated December 27,
1993, acknowledging receipt of a $7,000 cash contribution and the
religious items. Each letter contained a sentence stating: “We
welcome the opportunity to work with you to help maximize your
charitable contribution on your Schedule A, form 1040, and thank
you again for your generosity to our Diocesan Programs.”
In a letter dated April 4, 1994, Walzer acknowledged receipt
of the Kesslers, stating that the donation of the Kesslers was
made on October 1, 1993. This correspondence also included an
inventory of the Kesslers that was prepared by Donald C.
Brueggemann (Brueggemann). The Brueggemann inventory placed a
value on each Kessler and indicated that the total value of all
of the Kesslers was $900,430. The inventory did not contain any
valuation methodology, any rationale for the prices quoted, or
any reference to comparable sales. It provided only a
description of the Kesslers on a lot-by-lot basis.
Petitioner filed Federal income tax returns for 1993 and
1994 on September 30, 1994, and October 17, 1995, respectively.
On his 1993 return, petitioner reported adjusted gross income of
$1,555,648. He claimed charitable contributions of $13,997 in
cash and $949,030 in noncash property to the diocese. Petitioner
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