Barry John Sergeant and Christine M. Sergeant - Page 7

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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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