Robert and Karen O'Connor - Page 7




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          regarding Omega’s farm activity.  Petitioner never changed                  
          Omega’s farming methods or implemented the improvements suggested           
          by Collado or the agricultural experts.                                     
               Omega claimed deductions for contributions to CBR consisting           
          of the payment of Omega’s employees for the performance of                  
          services for the benefit of CBR.  The labor expenses were                   
          described as amounts for the building and/or maintenance of                 
          corrals, silos, a radius wall, the orchard, a septic system,                
          buildings, equipment, and grounds.  From 1990 to 1995, the                  
          amounts claimed by Omega as its section 170(c)(2) contributions             
          of Omega’s employees’ labor to CBR were as follows:                         
                           Year          Amount                                       
                           1990         $13,170                                       
                           1991         39,593                                        
                           1992         20,631                                        
                           1993         121,149                                       
                           1994         76,711                                        
                           1995         95,016                                        
          These amounts were passed through to and deducted by petitioners            
          subject to adjusted gross income limitations.                               
               In 1990, petitioners made contributions of property to CBR.            
          The donated items included two dismantled metal buildings, one              
          2,500-gallon butane tank, one Austin-Western Pettybone crane, one           
          Clark forklift, and one sheer press.  Petitioners valued these              
          items at $107,500.  Five of the six donated items were valued by            
          petitioners at over $5,000 each.  Petitioners attached a Form               
          8283, Noncash Charitable Contributions, to their 1990 Federal               





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