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provided by section 1016.
Neither Ms. Schadle, Mr. Tutor, nor Mr. Johnston was aware
that TMC had constructed a new building on KQC’s land with HHS’s
grant funds. Nor was any of them aware that KQC was reporting in
KQC’s 1999 return a charitable contribution in an amount equal to
the preliminary real estate appraisal (i.e., $1,025,000) set
forth in Mr. Mumford’s December 17, 1999 letter 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 constructed on that land by TMC.
Mr. Kaplan and Ms. Kaplan (collectively the Kaplans), Mr.
Marceron and Ms. Marceron (collectively the Marcerons), and Mr.
Caldwell and Ms. Caldwell (collectively the Caldwells) timely
filed their respective Forms 1040, U.S. Individual Income Tax
Returns, for 1999 (petitioners’ respective returns). In peti-
tioners’ respective returns, the Kaplans, the Marcerons, and the
Caldwells claimed the following amounts of noncash charitable
contribution deductions attributable to KQC’s claiming in KQC’s
1999 return a noncash charitable contribution to TMC of
$1,025,000:
Amount of Claimed
Petitioners Charitable Contribution
The Kaplans $608,850
The Marcerons 51,250
The Caldwells 364,900
(We shall refer to the respective noncash charitable contribution
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