- 42 -
On the instant record, we find that the quid pro quo which
the University and Mr. Signom considered the University to have
received in the final exchange transaction from petitioners as
the general partners of MHR Properties and Mr. Signom in his
individual capacity totaled $276,500. That quid pro quo was less
than the quid pro quo totaling $295,963 that the University and
Mr. Signom considered Mr. Signom to have received from the
University in that transaction.11
Based on our examination of the entire record in this case,
we find that the cancellation of MHR Properties’ St. Clair
property interests did not constitute a contribution or gift of
property to the University within the meaning of section
170(c).12 We further find on that record that petitioners have
11It is noteworthy that the July 22 document recited that
the cancellation of the Mumma/MHR Properties lease agreement,
including MHR Properties’ purchase option, was “mutually benefi-
cial” to the University and to MHR Properties and Mr. Signom and
Ms. Signom as the general partners of MHR Properties.
12Assuming arguendo that we were to have found that peti-
tioners established that the cancellation of MHR Properties’ St.
Clair property interests qualified as a contribution or gift to
the University within the meaning of sec. 170(c), on the record
before us, we find that petitioners have failed to show that they
satisfied certain of the recordkeeping and return requirements
for charitable contribution deductions prescribed by sec. 170(a)
and sec. 1.170A-13, Income Tax Regs.
The recordkeeping and return requirements for charitable
contribution deductions require a taxpayer, inter alia, to obtain
a qualified appraisal (qualified appraisal) for donated property
(except money and certain publicly traded securities) for which
the taxpayer claims a deduction in excess of $5,000. See sec.
1.170A-13(c)(1)(i) and (2)(i), Income Tax Regs. The qualified
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