Rhett Rance Smith and Alice Avila Smith, et al. - Page 16




                                        - 16 -                                        
          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              







Page:  Previous  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  Next 

Last modified: March 27, 2008