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(Mr. Johnston), who was a tax specialist with Ernst & Young in
2000 when KQC’s 1999 return was being prepared and who prepared
KQC’s 1999 return on the basis of information provided to him by
KQC. Mr. Tutor, inter alia, reviewed KQC’s 1999 return and
satisfied himself that he was able to sign that return as return
preparer.
During the course of preparing KQC’s 1999 return, Mr.
Johnston had discussions with Mr. Marceron about KQC’s claimed
noncash charitable contribution to TMC. In those discussions,
Mr. Marceron informed Mr. Johnston that KQC had contributed to
TMC, a nonprofit organization, a building located on the improved
property on Maple Street, which had a cost basis of $95,000 on
KQC’s books and an appraised value of $1 million. Mr. Marceron
explained to Mr. Johnston that the value of the building that KQC
claimed to have given to TMC had increased to $1 million because
TMC made improvements to that building. In the discussions that
Mr. Johnston had with Mr. Marceron about KQC’s claimed noncash
charitable contribution to TMC, Mr. Marceron indicated that he
believed that claiming a deduction with respect to such claimed
charitable contribution would be a “push”; that is to say, Mr.
Marceron believed that there was a substantial risk that respon-
dent would disallow any such claimed deduction.
Mr. Marceron completed portions, but not all, of Form 8283,
Noncash Charitable Contributions (Form 8283), with respect to the
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