Rhett Rance Smith and Alice Avila Smith, et al. - Page 45




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          contributed; the manner of acquisition and the date of                      
          acquisition; the cost or other basis of the property; and the               
          name, address and identifying number of the qualified appraiser             
          who signs the appraisal summary.  Section B of Form 8283 is the             
          form designed for the appraisal summary.                                    
               The Forms 8283 attached to the returns were in many respects           
          either improperly or incompletely prepared.  Zane and Shannon did           
          not attach a Schedule B to the Form 8283 that was attached to               
          their 1998 income tax return.  Instead they completed section A,            
          which is expressly intended to be used for noncash charitable               
          contributions worth $5,000 or less.  As a result, their 1998                
          return contained no declaration by appraiser and no                         
          acknowledgment of the donee.                                                
               On the Forms 8283 attached to Rance and LaRhea’s and Rhett             
          and Alice’s 2000 returns, Mr. Kramer signed the Declaration of              
          Appraiser and referred to an appraisal dated September 1, 1999,             
          that was not attached to the returns or shown to have existed.              
          Rance and LaRhea’s return reflected that an interest of 1.5988              
          percent of the partnership with a value of $145,000 was                     
          contributed to CCF.  The parties have now agreed and stipulated             
          that Lance and LaRhea contributed a 3.22-percent interest with a            
          total value of $145,000.  Rhett and Alice’s return reflected that           
          an interest of 2.2851 percent of the partnership with a value of            
          $100,000 was contributed to CCF.  The parties have now agreed and           







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