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Petitioners filed their joint 2001 Federal income tax return
on April 15, 2002, reporting a noncash charitable contribution of
$210,306.4 Attached to their return was a Form 8283, Noncash
Charitable Contributions. Form 8283 instructs the taxpayer to
provide, inter alia, a description of the donated property, the
date of its acquisition, and, if the property was sold in a
“bargain sale”, the amount the taxpayer received from the donee.
Petitioners’ Form 8283 describes the donated property as
“Farmland” and lists the date of acquisition as “Various”. It
does not identify the contribution as a bargain sale or indicate
that petitioners received payment from DALPF.
Form 8283 includes a section titled “Donee Acknowledgment”.
This section instructs the donee to acknowledge that it is a
qualified organization under section 170(c) and that it received
the property in question. Petitioners’ Form 8283 was not signed
by a representative of DALPF.
Form 8283 also includes a section titled “Declaration of
Appraiser”. This section instructs the appraiser of the donated
property to sign the following statement:
I declare that I am not the donor, the donee, a party
to the transaction in which the donor acquired the
property, employed by, or related to any of the
foregoing persons * * *. And, if regularly used by the
donor, donee, or party to the transaction, I performed
4 Because petitioners reported adjusted gross income of
$19,561, their claimed deduction was limited to $9,781.
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Last modified: May 25, 2011