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Rhett and Alice attached Form 8283 to their 2000 return and
in section B, part I, Information on Donated Property, described
the donated property as “2.2851% Units Interest Zerubbabel Ltd”,
stating that it had an appraised fair market value of $100,000.
The Declaration of Appraiser was signed by Mr. Kramer and
contains the statement that the appraisal date was September 1,
1999. No appraisal was attached to Rhett and Alice’s 2000
return, and no appraisal dated September 1, 1999, was provided to
respondent or the Court. No signature appeared in the Donee
Acknowledgment portion, part IV, of the first section B attached
to the return. A second section B was also attached to the 2000
return bearing the Donee Acknowledgment signature of Valerie
Cornelius on behalf of CCF. Also attached to the 2000 return was
an acknowledgment of the contribution from CCF, dated January 31,
2001, which included the statement “No goods and services were
provided for this donation.”
Rhett and Alice attached two Forms 8283, section B to their
2001 return and, in each, described the donated property as
“13.674% Units (Beneco Stock) Zerrubbable Ltd” with a stated
value of $290,000. The signature line of the Declaration of
Appraiser was blank on one of the forms. The other had the
handwritten notation “see attached 11/19/01 report Frank E. Koehl
Jr” with a typewritten address in Princeton, New Jersey, and a
typewritten appraisal date of November 19, 2001. Mr. Kramer made
the handwritten notation “see attached 11/19/01 report Frank E.
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Last modified: March 27, 2008