- 7 - "qualified appraiser", and (2) in addition to obtaining such appraisal, the taxpayer made a good faith investigation of the value of the contributed property. Sec. 6664(c)(2) and (3). Qualified appraisers and qualified appraisals are defined under the regulations under section 170(a)(1). Sec. 6664(c)(3). First, among the information to be included on a qualified appraisal is the date (or expected date) of the contribution. See sec. 1.170A-13(c)(3)(ii)(C), Income Tax Regs. The Hurt appraisal does not include the date or expected date of contribution of the boat to the donee. Second, there is insufficient evidence to determine whether Mr. Hurt is a qualified appraiser. See sec. 1.170A-13(c)(4), (c)(5), Income Tax Regs. (discussing what an appraisal summary is and the declarations required to be made by the preparer of the appraisal summary in order to qualify as a qualified appraiser).7 Last, there is no evidence that, in addition to obtaining the Hurt appraisal, petitioners made a good faith investigation of the value of the contributed property. Thus, the reasonable cause exception of section 6664(c) does not apply. The $75,100 claimed value of the boat exceeds 200 percent of the correct value (i.e., $22,125). Petitioners, therefore, are liable for the penalty pursuant to section 6662 for a substantial valuation misstatement. 7 An appraisal summary is not part of the record in this case.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011