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KQC filed KQC’s 1999 return, KQC was required to have TMC, the
purported donee, complete the donee acknowledgment in KQC’s Form
8283, such donee acknowledgment was left blank.9 In addition,
KQC’s Form 8283 did not contain: (1) KQC’s name and taxpayer
identification number, (2) the date and manner of KQC’s acquisi-
tion of the property purportedly contributed, and (3) the cost or
other basis of the property purportedly contributed, adjusted as
8(...continued)
preliminary real estate appraisal of KQC’s land, the 1958 school
building on that land as well as the improvements thereto made by
TMC, other improvements to KQC’s land made by TMC, and the new
building built on that land by TMC was $1,025,000.
9The donee acknowledgment in Form 8283 required the follow-
ing information to be provided by the charitable organization
receiving the claimed noncash charitable contribution:
This charitable organization acknowledges that it is a
qualified organization under section 170(c) and that it
received the donated property as described in Section
B, Part I [of Form 8283], above on <___________________
(Date)
Furthermore, this organization affirms that in the
event it sells, exchanges, or otherwise disposes of the
property described in Section B, Part I (or any portion
thereof) within 2 years after the date of receipt, it
will file Form 8282, Donee Information Return, with the
IRS and give the donor a copy of that form. This
acknowledgment does not represent agreement with the
claimed fair market value
Does the organization intend to use the property for an
unrelated use? . . . . . . . . . . . . . < G Yes G No
An authorized representative of the charitable organization
receiving the claimed noncash charitable contribution was re-
quired (1) to provide in the donee acknowledgment in Form 8283
the name of such organization, its employer identification
number, and its address and (2) to sign and date such donee
acknowledgment.
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