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"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.
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Last modified: May 25, 2011