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the majority of my appraisals during my tax year for
other persons.
Also, I declare that I hold myself out to the public as
an appraiser or perform appraisals on a regular basis;
and that because of my qualifications as described in
the appraisal, I am qualified to make appraisals of the
type of property being valued. * * * Furthermore, I
understand that a false or fraudulent overstatement of
the property value as described in the qualified
appraisal or this * * * [Form 8283] may subject me to
the penalty under section 6701(a) (aiding and abetting
the understatement of tax liability). * * *
The Form 8283 attached to petitioners’ tax return was not signed
by an appraiser.
Respondent examined petitioners’ 2001 tax return and sent
petitioners an Information Document Request (IDR) in May 2004.
The IDR requests a Form 8283 signed by the appraiser and the
donee, as well as complete real estate appraisals for Procko Farm
and Webber Farm. The IDR advises petitioners to “be sure that
the appraisal reports that you submit are ‘qualified appraisals’
as defined in Treasury Regulation, Section 1.170A-13(c)(3).”
In July 2004, petitioners provided respondent with a
separate Form 8283 for each of the properties. The Forms 8283
were signed by a representative of DALPF but were not signed by
an appraiser. A letter from William Denman, an attorney for
DALPF, explains that the appraisers from RPC were not willing to
sign the Forms 8283.
Respondent issued petitioners a notice of deficiency in June
2005. Respondent disallowed in full the claimed deduction and
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