- 30 - (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 thePage: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
Last modified: May 25, 2011