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Attached to each petitioner's 1994 return was a Form 8283,
Noncash Charitable Contributions, in support of the charitable
contribution deduction claimed for the transfer of intangible
assets to SMF. Part III, Certification of Appraiser, of Section
B of the Form 8283 was executed by Houlihan and dated April 7,
1995, the date of the Houlihan appraisal. Part IV, Donee
Acknowledgment, of Section B of the Form 8283 was executed on
behalf of SMF by Karl Silberstein, "VP", and dated July 18, 1995.
On its 1994 return, Form 990, Return of Organization Exempt
From Income Tax, SMF did not report as contributions received any
donations of intangible assets or goodwill from petitioners or
any other SWMG physician.
VI. Dutcher Appraisal
After respondent commenced an examination of petitioners'
1994 returns, petitioners' counsel in this case retained another
appraiser, Ernest E. Dutcher, managing member of National
Business Appraisers, L.L.C., to "independently determine the
market value of the intangible assets of SWMG as of * * *
November 1, 1994, assuming a sale to a qualified buyer who could
either be a for-profit entity or a 501(c)(3) corporation." Mr.
Dutcher's appraisal (Dutcher appraisal) postulated that the value
of the aggregate intangibles of the SWMG physicians was equal to
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