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date, including extensions, on which petitioners’ joint return
was due was October 15, 1992.
In their joint return, petitioners deducted $111,500 for a
claimed noncash charitable contribution to the University. As
required, petitioners filed Form 8283, Noncash Charitable Contri-
butions (Form 8283), with their joint return. Petitioners
completed section B, Appraisal Summary, of Form 8283 relating to
a claimed charitable contribution deduction of more than $5,000
per item. Petitioners attached Mr. Nizny’s letter dated October
13, 1992, and the final acknowledgment document to Form 8283.
They did not attach any other documents to Form 8283 and did not
otherwise disclose in their joint return all of the August 1
property transfers that were effected as of August 1, 1991,
pursuant to the final property exchange agreement.
In Part I of Section B of Form 8283, entitled “Information
on Donated Property”, petitioners described the claimed donated
property as “OPTION TO PURCHASE REAL ESTATE AT LESS THAN FAIR
MARKET VALUE” and reported that its appraised fair market value
was $111,500. Mr. Nizny signed the “Certification of Appraiser”
in Part III of Section B of Form 8283. The date of the appraisal
of the “OPTION TO PURCHASE REAL ESTATE AT LESS THAN FAIR MARKET
VALUE” as reported in Part III of Section B of Form 8283 was
October 13, 1992. Mr. Nizny’s address as reported in Part III of
Section B of Form 8283 was an address to which he moved after
October 13, 1992.
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