- 31 -
purported contribution to TMC and sent it to Mr. Johnston for his
review. Mr. Johnston reviewed Form 8283 that Mr. Marceron had
prepared and informed Mr. Marceron, inter alia, that Part IV,
Donee Acknowledgment (donee acknowledgment), had to be completed
by TMC, the purported donee, before KQC included it, as required,
with the tax return that it was filing for 1999.
KQC, and not Ernst & Young, handled the actual filing of
KQC’s 1999 return. In that return, KQC claimed a noncash chari-
table contribution of $1,025,000. In the section entitled
“Deductions” in Schedule K, Partners’ Shares of Income, Credits,
Deductions, etc., KQC showed a charitable contribution of
$1,025,000. In an explanatory statement attached to that sched-
ule, KQC described that claimed contribution as “TEXAS MIGRANT
SCHOOL PROPERTY--HELENA, OH”. Form 8283 that KQC included as
part of KQC’s 1999 return (KQC’s Form 8283) indicated that the
name of the organization to which KQC claimed it gave certain
noncash property was “Texas Migrant School Property” and gave the
following description of the property that KQC claimed it gave to
TMC: “Maple Street, Helena, Sandusky County, OH”. KQC’s Form
8283 indicated that the donated property was “Real Estate” and
that the condition of such property was “good”. KQC’s Form 8283
showed the fair market value of the claimed donated property as
$1,025,000.8 In disregard of Mr. Johnston’s advice that, before
8Mr. Mumford’s December 17, 1999 letter indicated that a
(continued...)
Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 NextLast modified: May 25, 2011