- 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 (continued...)Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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