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valued the boat at $500, with most of the value attributable to
the trailer.
After obtaining the appraisal, The Salvation Army’s local
corps commander determined the sales price for the boat. The
boat was subsequently sold by The Salvation Army for $500.
C. Petitioners’ Income Tax Return
On October 10, 1997, petitioners filed a Form 1040, U.S.
Individual Income Tax Return, for 1996. On their 1996 return,
petitioners claimed noncash charitable contributions of $100,000
for the Winter Haven property and $10,000 for the boat.
Petitioners attached the second page of two Forms 8283, Noncash
Charitable Contributions, to their 1996 return. The second page
of the Form 8283 for the Winter Haven property listed the
appraised fair market value as $200,000, specified the appraisal
date as January 1, 1997, and was signed by the pastor of
Community Church as the appraiser. The second page of the Form
8283 for the boat listed the fair market value as $10,000 and was
not signed by an appraiser.
Petitioners’ 1996 return was prepared by Mr. Nunez. Mr.
Nunez had prepared petitioners’ income tax returns for nearly 40
years. As previously noted, Mr. Nunez advised petitioners of the
part sale/part gift arrangement with respect to the Winter Haven
property. Mr. Nunez was not aware of the contribution of the
boat until he obtained information from petitioners necessary to
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