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basis of photographs and other evidence in the record, that the
appraisal report inadequately describes the physical condition of
the items. See sec. 1.170A-13(c)(3)(ii)(B), Income Tax Regs.
Additionally, the appraisal does not contain the method of
valuation that the appraiser used when attributing values to the
property. See sec. 1.70A-13(c)(3)(ii)(J), Income Tax Regs.
Finally, the appraisal does not contain the specific basis for
the valuation. See sec. 1.170A-13(c)(3)(ii)(K), Income Tax Regs.
Petitioners were unable to explain the absence of the required
information. The items were generally described as “new”,
“used”, or “discard”, and in a limited number of cases “good”,
“fair”, or “dismantled”. Without a more detailed description the
appraiser’s approach and methodology cannot be evaluated. In
that regard, the appraiser was not called to testify, and no
other appraisers were offered by petitioners. Accordingly,
petitioners have not fully complied with the requirements imposed
by the regulations. See sec. 1.170A-13(c), Income Tax Regs.
Although petitioner testified as to the condition of the
contributed items, his testimony was evasive on cross-
examination, and his testimony was inconsistent with photographic
evidence of the contributed property. Many of the items
contributed by petitioners, such as mechanized farm equipment,
industrial machinery, fuel tanks, and vehicles appear to be
rusted and in a state of disrepair. Petitioners offered no sales
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