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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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