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(3) Appraisal summary.--For purposes of this
subsection, the appraisal summary shall be in such form
and include such information as the Secretary
prescribes by regulations. Such summary shall be
signed by the qualified appraiser preparing the
qualified appraisal and shall contain the TIN of such
appraiser. Such summary shall be acknowledged by the
donee of the property appraised in such manner as the
Secretary prescribes in such regulations.
(4) Qualified appraisal.--The term “qualified
appraisal” means an appraisal prepared by a qualified
appraiser which includes--
(A) a description of the property appraised,
(B) the fair market value of such property on
the date of contribution and the specific basis for the
valuation,
(C) a statement that such appraisal was prepared
for income tax purposes,
(D) the qualifications of the qualified
appraiser,
(E) the signature and TIN of such appraiser, and
(F) such additional information as the Secretary
prescribes in such regulations.
The principal objective of DEFRA section 155 was to allow
the Commissioner to obtain sufficient return information in order
to deal more effectively with the prevalent use of charitable
contribution overvaluations. Hewitt v. Commissioner, 109 T.C.
258, 265 (1997) (citing S. Comm. on Finance, Deficit Reduction
Act of 1984, Explanation of Provisions Approved by the Committee
on March 21, 1984, S. Prt. 98-169 (Vol. I), at 444-445 (S. Comm.
Print 1984), and Staff of Joint Comm. on Taxation, General
Explanation of the Revenue Provisions of the Deficit Reduction
Act of 1984 (J. Comm. Print 1985)), affd. without published
opinion 166 F.3d 332 (4th Cir. 1998).
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