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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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