- 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...)           
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