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petitioner engaged the two appraisers with the intent to inflate
artificially the amount of petitioners’ charitable contribution
deduction. See sec. 1.170A-13(c)(5)(ii), Income Tax Regs.
Section 6659(f)(2)(B) requires the taxpayer to have made a
good faith investigation of the value of the contributed property
in addition to the appraisal. At the advice of petitioners’
accountant, petitioner obtained two appraisals. The first was
performed by Rothschild and the second by Rose. Petitioner
ultimately used Rose's appraisal to value the charitable
contribution. Petitioner obtained Rothschild's name from the
American Society of Appraisers first and then later obtained
Rose's name either from Rothschild or from the Appraisers
Association of America. In 1985, both Rose and Rothschild were
seemingly well-respected appraisers. Several years earlier,
Rothschild had been recommended to Everett by the IRS for an
entirely different appraisal in the early 1980's of movie
memorabilia unrelated to this case. When Everett inquired at
that time about Rothschild at the American Film Institute, as a
matter of due diligence, he received a favorable recommendation.
In 1985, Rose was a member of the board of the Appraisers
Association of America and a senior member of the American
Society of Appraisers. He also listed an impressive number of
recent clients, including The Brooklyn Children's Museum, the
American Museum of Natural History, and Chemical Bank. Rose's
curriculum vitae and the recommendations that petitioner received
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