Rhett Rance Smith and Alice Avila Smith, et al. - Page 10




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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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