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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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