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information concerning the transfer, including petitioners’ “cost
or adjusted basis” in the shares, $33,338, the fair market value
of the shares, $553,847, and a statement of the method used to
determine the fair market value: “Sales of other shares at same
time”. The portion of the Form 8283 that provides for the
certification of an appraiser is without entries. No appraisal
summary with respect to the shares is attached to the Form 8283
or otherwise included with the Form 1040. Because of
contribution limitations, petitioners claimed a deduction on the
Form 1040 on account of the transfer in the amount of $88,879.
They claimed additional deductions of $152,692, $221,066, and
$56,906 on their 1995, 1996, and 1997 income tax returns,
respectively.
Sale of the Shares
The statement on the Form 8283 that the fair market value of
the shares was $553,847 is based on the foundation’s sale of the
shares (for that amount) on January 5, 1995, to First National of
Nebraska, Inc., a Nebraska corporation, pursuant to an agreement
of merger involving Bancorp.
Bancorp and the Bank
On the transfer date, Bancorp was a bank holding company,
owning all of the issued and outstanding shares of stock of Union
Colony Bank, Greeley, Colorado, a state-chartered Colorado bank
(the bank). On that date, shares of Bancorp were not listed on
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Last modified: May 25, 2011