Bruce K. and Marina V. Ney - Page 13

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                    (B) A description of the property in sufficient                   
               detail for a person who is not generally familiar with                 
               the type of property to ascertain that the property                    
               that was appraised is the property that was                            
               contributed;                                                           
                        *     *     *     *     *     *     *                         
                    (D) The manner of acquisition (e.g., purchase,                    
               exchange, gift, or bequest) and the date of acquisition                
               of the property by the donor * * *;                                    
                        *     *     *     *     *     *     *                         
                    (H) For charitable contributions made after June                  
               6, 1988, a statement explaining whether or not the                     
               charitable contribution was made by means of a bargain                 
               sale and the amount of any consideration received from                 
               the donee for the contribution;                                        
                    (I) The name, address, and * * * the identifying                  
               number of the qualified appraiser who signs the                        
               appraisal summary * * *;                                               
                    (J) The appraised fair market value of the                        
               property on the date of contribution;                                  
                    (K) The declaration by the appraiser described in                 
               paragraph (c)(5)(i) of this section [regarding the                     
               imposition of a penalty under section 6701 for aiding                  
               and abetting an understatement of tax liability];                      
                        *     *     *     *     *     *     *                         
                    (M) Such other information as may be specified by                 
               the form.                                                              
          Sec. 1.170A-13(c)(4)(i) and (ii), Income Tax Regs.                          
          II. Petitioners’ Compliance With the Substantiation Requirements            
               A.  Strict Compliance                                                  
               Petitioners concede that they did not strictly comply with             
          the substantiation requirements in the regulations.  Indeed, the            
          2000 appraisals were made more than 60 days before the date of              





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