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representative of CCF assigning and acknowledging a transfer of an
FLP interest with a stated value of $90,000 as of December 31,
1998. The 1998 return did not have any reference to whether
Zane and Shannon received goods or services in connection with
their contribution.
During 1998, Zane and Shannon assigned “an economic interest
in that percentage of their limited partnership interest in the *
* *[Mustard Seed] which has a value of $90,000 as of December 31,
1998, including all interest in the capital * * * of the
partnership, but specifically excluding any right * * * to
exercise any vote”. Form 8283 attached to Zane and Shannon’s 2001
return contains the statement that the donated property was
“8.864% units of (Beneco stock) the Mustard Seed LP” with an
appraised fair market value of $188,000.
Section B, part III, Declaration of Appraiser, on Zane and
Shannon’s Form 8283, attached to their 2001 return contained the
handwritten notation “see Ltr Attached Frank E. Koehl Jr” on the
line to be used for the signature of the appraiser. The
Declaration of Appraiser and Donee Acknowledgment appeared to be
signed by Mr. Koehl, and Valerie Cornelius for CCF. The
typewritten date of appraisal in part III was “11/19/2001”. Mr.
Kramer made the handwritten notation “see Ltr Attached Frank E.
Koehl Jr”. Also attached to Zane and Shannon’s 2001 return was a
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Last modified: March 27, 2008