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Koehl Jr”. No appraisal report was attached to the 2001 return.
Attached to the 2001 return was a letter dated November 19, 2001,
from Mr. Koehl, stating that the value of Beneco stock, as of
March 31, 2000, was $8,500 per share. No detail or explanation
as to how the valuation was done was attached to the 2001 return.
Also attached to the 2001 return was an assignment of a portion
of their FLP by Rhett and by Alice, along with consents and
acknowledgment by the president of CCF, signed and dated in late
December 2001.
Rhett and Alice assigned an interest in Zerubbabel to
Crossmen Ministries in 2002 and claimed a $247,500 charitable
deduction for that contribution. Crossmen Ministries was a Texas
nonprofit corporation that petitioners organized during 2002.
LaRhea, Rance, and Rhett were the officers of Crossmen
Ministries. During 2002, Crossmen Ministries was affiliated with
World Bible Way Fellowship, Inc. (World Bible Way). During 2002,
World Bible Way was a section 501(c)(3) tax-exempt entity which
held a group exemption letter, permitting subordinate entities
not listed as tax exempt to qualify for tax-exempt status because
of their affiliation with World Bible Way.
Rhett and Alice did not donate Beneco stock to World Bible
Way or Crossmen Ministries during the years at issue. Rhett and
Alice attached section B of Form 8283 to their 2002 return. It
described the donated property as “11.67% Of FLP Beneco Stk” with
an appraised fair market value of $247,500. That Form 8283
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Last modified: March 27, 2008