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to the typed date December 29, 2000. Attached to Rance and
LaRhea’s 2000 return was a letter, dated January 31, 2001,
thanking them for their charitable donation on December 29, 2000,
and stating that “No goods or services were provided for this
donation.”
Likewise, Rance and LaRhea attached section B of Form 8283 to
their 2001 return and reported the donated property as “11.272%
Units (BENECO Stock) JIREH Ltd” with an appraised fair market
value of $480,000. Mr. Kramer made the handwritten notation on
part III, Declaration of Appraiser, of Rance and LaRhea’s 2001
Form 8283 “see attached 11/19/01 report 11/19/2001 Frank E. Koehl
Jr.” The Form 8283 was not signed by Frank E. Koehl, Jr. (Mr.
Koehl). Also attached to Rance and LaRhea’s 2001 return was a
one-page letter, dated November 19, 2001, from Mr. Koehl, to Rance
referring to an $8,500-per-share valuation of Beneco as of March
31, 2000. No such appraisal was attached to Rance and LaRhea’s
2001 return. The Donee Acknowledgment, part IV on Form 8283 for
2001, was signed by Valerie Cornelius, and the title “President”
and the date “12/26/2001” were typed next to her name. The
typewritten title “President” and the date “12/26/2001” were both
crossed out, and the title “Treasurer” and the date “4/13/2002”
were handwritten. No letter of acknowledgment, gratitude, or
statement that no goods or services were received was attached to
the 2001 return.
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Last modified: March 27, 2008