Rhett Rance Smith and Alice Avila Smith, et al. - Page 9




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          interests.  Petitioners paid annual administrative fees to CCF.             
          From 1995 through 2001, Rance and LaRhea assigned interests in              
          Jireh to CCF and claimed the following noncash charitable                   
          contributions deductions:                                                   
                                   Percent Assigned         Claimed                   
                    Date            Per Tax Return       Contribution                 
                  12/20/95             10.9157%            $350,000                   
                  12/29/97              9.9133              Unknown                   
                  12/29/00              1.5988             145,000                    
                12/31/01               11.272              480,000                    
          Although Form 8283, Noncash Charitable Contributions, for 2000              
          indicated that an interest of 1.5988 percent had been contributed           
          to CCF, the actual percentage contributed was 3.22 percent.                 
               Pursuant to Rance and LaRhea’s request, during the period              
          1995 to 2002, CCF directed their contributed interests in Jireh to          
          Zacchaeus.  During the years 1998 through 2001, Rance and LaRhea            
          did not transfer any Beneco stock to CCF.  Rance and LaRhea                 
          attached section B of Form 8283 to their 2000 return and described          
          the donated property as “1.5988% Units Jireh Ltd” with an                   
          appraised fair market value of $145,000.  The Declaration of                
          Appraiser, part III on Form 8283 for 2000, was signed by Mr.                
          Kramer and stated that the appraisal date was September 1, 1999.            
          No such appraisal was attached to Rance and LaRhea’s 2000 return            
          or made a part of the record.                                               
               The Donee Acknowledgment, part IV on Form 8283 for 2000, was           
          signed by Valerie Cornelius, Director of Operations for CCF, next           





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