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income tax return. The Form 8283 was signed by Jane Dolan
(Dolan), a California probate referee, in support of the claimed
values. Petitioners were unable to deduct all of the property
donations claimed for 1990 because of adjusted gross income
limitations.
In 1991, petitioners donated various items to CBR and
claimed a deduction of $640,888. Petitioners valued many of the
items at more than $5,000 each. Petitioners attached an
equipment appraisal letter, a list of the appraised items, and a
Form 8283 to their 1991 Federal income tax return. Dolan again
signed as appraiser. The Form 8283 contained the statement that
the items had been acquired by petitioners between 1964 and 1991,
and that all items were purchased for amounts equal to or greater
than their appraised values. The items listed, among others,
included the following: Mobile buildings; water tanks; bailers;
feed; weigh scales; stereo equipment; an aluminum can machine;
compactors; pumps; motors; cargo containers; a fire engine;
freezers; rubbish bins; canned drink machines; appliances; air-
conditioners; kitchen equipment; cattle trailers; conveyors;
flatbed trailers; fencing; vehicles; street sweepers; water
troughs; furniture; a glass crusher; gates; rolltop bins; a
security system; and animals. Each item was: Categorized by its
general location at CBR; described as new, used, or discard; and
assigned a value. Many of the items were rusted and in a state
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