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one-page November 19, 2001, letter from Mr. Koehl to Rance
referring to an $8,500-per-share valuation for Beneco as of March
31, 2000. Also attached to Zane and Shannon’s 2001 return was an
acknowledgment from CCF of its receipt of the limited partnership
interest, advising that “No goods or services were provided for
this donation.” Finally, there was attached an assignment of an
FLP interest in Mustard Seed, along with a signed consent from CCF
by its president.
From 1995 through 2001, Rhett and Alice assigned interests in
Zerubbabel to CCF and claimed corresponding noncash charitable
contribution deductions on their personal income tax returns, as
follows:
Percent Assigned Claimed
Date Per Tax Return Contribution
12/20/95 11.587% $185,000
12/29/97 3.92 Unknown
12/29/00 2.2851 100,000
12/31/01 13.674 290,000
Although Rhett and Alice’s Form 8283 for 2000 contained the
statement that an interest of 2.2851 percent had been contributed
to CCF, the actual percentage contributed was 4.57 percent.
Pursuant to Rhett and Alice’s request, CCF directed their 1995-
2001 assigned interests in their FLP (Zerubbabel) to Zacchaeus.
Rhett and Alice did not donate Beneco stock to CCF during the
years 1998 through 2001.
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Last modified: March 27, 2008