Rhett Rance Smith and Alice Avila Smith, et al. - Page 5




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               Petitioners J. Zane Smith (Zane) and Shannon R. Creese Smith           
          (Shannon) are married and resided in Earlville, New York, at the            
          time their petition was filed.  They timely filed Forms 1040 for            
          1998, 1999, 2000, and 2001.  On April 15, 2005, respondent sent             
          notices of deficiency to Zane and Shannon for their 1998, 1999,             
          2000, and 2001 tax years.                                                   
               Rance and LaRhea Smith are the parents of Rhett and Zane               
          Smith.                                                                      
          Noncash Charitable Contributions                                            
               Each couple claimed deductions for noncash charitable                  
          contributions of interests in their family limited partnership              
          (FLPs) which, essentially, was to hold interests in their closely           
          held, family-owned Arizona C corporation Beneco, Inc. (Beneco).             
          Beneco had been incorporated in 1989 with 1,000 initially issued            
          shares of stock, held as follows:                                           
                    Petitioners             Shares                                    
                    Rance                    250.5                                    
                    LaRhea                   250.5                                    
                    Rhett and Alice          249.5                                    
                    Zane and Shannon      249.5                                       
                    Total          1,000.0                                            
                                                                                     
               Beneco’s business was to provide a qualified retirement plan           
          and trust and qualified health and welfare trust services to                
          contractors who work under prevailing State and Federal wage laws,          
          including the Federal Davis-Bacon Act.  For its taxable years               
          ended March 31, 1997 through 2004, Beneco did not pay a dividend.           







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