John T. and Linda L. Hewitt - Page 9

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          requirements of section 1.170A-13, Income Tax Regs., and relieved           
          them of any obligation to obtain a qualified appraisal.                     
               It is clear that petitioners did not obtain any qualified              
          appraisal, and no summary of any such appraisal was submitted               
          with the returns.  The returns only reflected gifts of stock                
          without identifying the gifts as Jackson Hewitt stock, without              
          any indication of the number of shares, and setting forth only              
          the cost and claimed values.  The question is whether petitioners           
          satisfied the appraisal requirements of the statute and the                 
               Petitioners rely on Bond v. Commissioner, 100 T.C. 32                  
          (1993), to sustain their position that a qualified appraisal is             
          not a requirement under the circumstances herein.  In that case,            
          respondent challenged a charitable deduction for failure to                 
          obtain a qualified appraisal prior to filing the return.  The               
          parties stipulated there was no valuation overstatement.  We                
          found that the taxpayers had had the subject property, two                  
          blimps, appraised by a qualified appraiser within the specified             
          time frame, and that substantially all of the information                   
          required by respondent's regulations, section 1.170A-13(c)(3)(i),           
          Income Tax Regs., was contained in an appraisal summary, signed             
          by a qualified appraiser,9 set forth in the Form 8283 attached to           

               9  The only omitted item of required information was the               
          qualifications of the appraiser, which were promptly furnished to           
          respondent at the beginning of the audit of the return.  See Bond           

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