John C. and Tate M. Todd - Page 3




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                                  FINDINGS OF FACT                                    
               Some facts have been stipulated and are so found. The                  
          stipulations of facts, with accompanying exhibits, are                      
          incorporated herein by this reference.                                      
          Residence                                                                   
               Petitioners resided in Greeley, Colorado, at the time the              
          petition was filed.                                                         
          The Foundation and Contribution Thereto                                     
               On December 20, 1994, petitioners formed the Todd Family               
          Foundation (the foundation), a Colorado nonprofit corporation.              
               On December 27, 1994, petitioner John C. Todd (petitioner)             
          transferred 6,350 shares of stock (the transfer date, the                   
          transfer, and the shares, respectively) in Union Colony Bancorp             
          (Bancorp), a Colorado corporation, to the foundation.  On the               
          transfer date, the foundation was a private foundation (as                  
          defined in section 509(a)), other than a private foundation                 
          described in section 170(b)(1)(E).                                          
          Petitioners’ Tax Returns                                                    
               Petitioners filed a Form 1040, U.S. Individual Income Tax              
          Return (the Form 1040), for 1994.  In calculating their taxable             
          income shown on the Form 1040, petitioners claimed a deduction              
          for a charitable contribution on account of the transfer.                   
          Attached to the Form 1040 is a Form 8283, Noncash Charitable                
          Contributions (the Form 8283), on which petitioners provided                




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