- 7 - 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 FederalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011