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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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Last modified: March 27, 2008