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contained no Declaration of Appraiser, and no appraisal is
attached. The name and address of the charitable donee was
typewritten in section B, part IV, Donee Acknowledgment, but no
signature appeared thereon.
Also attached to Rhett and Alice’s 2002 return was a
document titled “Assignment of Limited Interest in Zerubbabel
Limited Partnership with Consent Attached” wherein Alice, as a
limited partner of Zerubbabel, assigned an interest in the FLP to
Crossmen Ministries. That typewritten document reflected, in two
separate locations, the value of the interest to be $91,050 as of
December 27, 2002. However, both the $91,050 values were crossed
out by hand and “$123,750” was handwritten in its place, along
with three sets of initials. The document reflected that Alice
signed the document on December 27, 2002, and Crossmen Ministries
accepted the assignment to be effective as of December 27, 2002.
Mr. Kramer served as petitioners’ C.P.A. for the period 1995
through 2002. He prepared individual income tax returns,
corporate returns, partnership returns, payroll tax returns,
annual reports, personal property tax returns, and other
documents for petitioners and their related entities. Mr.
Kramer, at the times he was responsible for the preparation of
petitioners’ tax returns, was aware of section 170 and the
reporting requirements for noncash charitable contributions
during the years at issue. He was also aware that the noncash
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Last modified: March 27, 2008