John T. and Linda L. Hewitt - Page 7

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          It incorporated many of the provisions of the Senate version but            
          left the details of implementation to regulations to be issued by           
          the Secretary of the Treasury.  The provisions relevant to this             
          case state:                                                                 
               Sec. 155.  Substantiation of Charitable Contributions;                 
               Modifications of Incorrect Valuation Penalty.                          
                    (a)  Substantiation of Contributions of                           
                         (1)  In general.--Not later than December 31,                
                    1984, the Secretary shall prescribe regulations                   
                    under section 170(a)(1) of the Internal Revenue                   
                    Code of 1954, which require any individual,                       
                    closely held corporation, or personal service                     
                    corporation claiming a deduction under section 170                
                    of such Code for a contribution described in                      
                    paragraph (2)--                                                   
                              (A) to obtain a qualified appraisal for                 
                         the property contributed,                                    
                              (B)  to attach an appraisal summary to                  
                         the return on which such deduction is first                  
                         claimed for such contribution, and                           
                              (C) to include on such return such                      
                         additional information (including the cost                   
                         basis and acquisition date of the contributed                
                         property) as the Secretary may prescribe in                  
                         such regulations.                                            
                    Such regulations shall require the taxpayer to                    
                    retain any qualified appraisal.                                   
                         (2)  Contributions to which paragraph (1)                    
                    applies.--For purposes of paragraph (1), a                        
                    contribution is described in this paragraph--                     
                              (A)  if such contribution is of property                
                         (other than publicly traded securities), and                 
                              (B)  if the claimed value of such                       
                         property (plus the claimed value of all                      

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