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donor, or person a written statement containing the
material required by subsection (b). Such statement
shall be furnished not later than 45 days after the
later of the date of such request or the date of such
determination or proposed determination.
(b) Contents of Statement.--A statement required
to be furnished under subsection (a) with respect to
the value of an item of property shall--
(1) explain the basis on which the valuation was
determined or proposed,
(2) set forth any computation used in arriving
at such value, and
(3) contain a copy of any expert appraisal made
by or for the Secretary.
Initially, we find it significant that section 7517 does not
include an enforcement mechanism. Although petitioner has
suggested that respondent's failure to comply with section 7517
may provide grounds for holding the notice of deficiency invalid,
petitioner has failed to cite any authority for this proposition
and we are aware of none. In the absence of express language
declaring that a notice of deficiency will be deemed invalid as a
consequence of respondent's failure to comply with a written
request under section 7517, we will not graft such an extreme
remedy onto the provision.9
9 On the whole, petitioner's reliance on sec. 7517 seems
superficial. Although the District Director may not have
responded to petitioner's request pursuant to sec. 7517, we note
that petitioner's counsel was apparently provided with a copy of
the revenue agent's report on or about July 27, 1995. Moreover,
our Rules provide the means for petitioner to obtain such
information either through the required informal exchange of
(continued...)
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