John T. and Linda L. Hewitt - Page 10

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          their return.  Accordingly, we held that the taxpayers had                  
          substantially complied with the requirements of the statute and             
          the regulations even though a separate appraisal had not been               
          obtained and the qualifications of the appraiser were omitted               
          from the appraisal summary attached to the return.                          
               In so holding, we stated:                                              
               the essence of section 170 is to allow certain                         
               taxpayers a charitable deduction for contributions made                
               to certain organizations. * * * However, the reporting                 
               requirements [of section 1.170A-13, Income Tax Regs.,]                 
               do not relate to the substance or essence of whether or                
               not a charitable contribution was actually made.  * * *                
               [Bond v. Commissioner, 100 T.C. at 41.]                                
          As a consequence, we concluded that the reporting requirements of           
          section 1.170A-13, Income Tax Regs, were directory, not                     
          mandatory, and therefore, that these requirements could be met by           
          substantial, rather than strict, compliance.  Bond v.                       
          Commissioner, 100 T.C. at 41.  In effect, we held that the                  
          appraisal summary itself constituted the required appraisal.  In            
          this connection, we note that the appraisal requirements may not            
          be entirely procedural so as to justify the application of the              
          substantial compliance rules under any and all circumstances.               
          See Atlantic Veneer Corp. v. Commissioner, 812 F.2d 158, 160-161            
          (4th Cir. 1987), affg. 85 T.C. 1075 (1985).                                 
               We find nothing in Bond v. Commissioner, supra, which                  
          relieves petitioners of the requirement of obtaining a qualified            

          v. Commissioner, 100 T.C. 32, 41-42 (1993).                                 

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