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market value of the property on the date of contribution,
information identifying the donor and donee, information
identifying the qualified appraiser signing the appraisal
summary, and a prescribed appraiser declaration.
Among the records retention requirements set forth in
section 1.170A-13(b)(2)(ii), Income Tax Regs., is that, if the
value of the contributed property was determined by appraisal, a
copy of the signed appraisal report be retained.
The term “publicly traded securities” is defined for
purposes of section 1.170A-13(c), Income Tax Regs., in
subparagraph (7)(xi) thereof. In pertinent part, that definition
is as follows:
(xi) Publicly traded securities. (A) In general.
* * * the term “publicly traded securities” means
securities * * * for which (as of the date of the
contribution) market quotations are readily available
on an established securities market. For purposes of
this section, market quotations are readily available
on an established securities market with respect to a
security if:
(1) The security is listed on the New York Stock
Exchange, the American Stock Exchange, or any city or
regional exchange in which quotations are published on
a daily basis, including foreign securities listed on a
recognized foreign, national, or regional exchange in
which quotations are published on a daily basis;
(2) The security is regularly traded in the
national or regional over-the-counter market, for which
published quotations are available; or
(3) The security is a share of an open-end
investment company (commonly known as a mutual fund)
registered under the Investment Company Act of 1940, as
amended (15 U.S.C. 80a-1 to 80b-2), for which
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