John T. and Linda L. Hewitt - Page 11

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          appraisal.  Such a requirement is statutorily imposed by section            
          155(a)(1)(A), and its impact is reflected in the legislative                
          history of that provision.  See H. Conf. Rept. 98-861, at 995-              
          996 (1984), 1984-3 C.B. (Vol. 2) 1, 249-250, stating:                       
               pursuant to present law (sec. 170(a)(1)), which                        
               expressly allows a charitable deduction only if the                    
               contribution is verified in the manner specified by                    
               Treasury regulations, no deduction is allowed for a                    
               contribution of property for which an appraisal is                     
               required under the conference agreement unless the                     
               appraisal requirements are satisfied.                                  
                        *     *     *     *     *     *     *                         
                    For donations of property as to which the donor                   
               appraisal requirements apply, the donor must obtain and                
               retain a qualified written appraisal by a qualified                    
               appraiser for the property contributed and must attach                 
               a signed appraisal summary to the return on which the                  
               deduction is first claimed (with such other information                
               as prescribed by regulations).                                         

               Petitioners herein furnished practically none of the                   
          information required by either the statute or the regulations.              
          Given the statutory language and the thrust of the concerns about           
          the need of respondent to be provided with appropriate                      
          information in order to alert respondent to potential                       
          overvaluations, see infra p. 13, petitioners simply do not fall             
          within the permissible boundaries of Bond v. Commissioner, supra,           
          where an appraisal summary, which was completed by a qualified              
          appraiser, contained most of the required information and could             
          therefore be treated as a written appraisal, was attached to the            
          return.  Cf. D'Arcangelo v. Commissioner, T.C. Memo. 1994-572               

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