Estate of Doris L. Rickman, Deceased, Doris K. Rickman, Executrix - Page 18

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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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