Gabe W. Stewart, Jr., and Doris R. Stewart - Page 6

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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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