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contribution; they do not state that they were prepared for
income tax purposes; and they do not appraise Procko Farm and
Webber Farm on the date of contribution. See sec. 1.170A-
13(c)(3)(i)(A), (G), (I), Income Tax Regs. In addition,
petitioners concede that RPC was not a qualified appraiser
because RPC was employed by DALPF. See sec. 1.170A-13(c)(5)(iv),
Income Tax Regs.
With respect to the 2005 appraisals by DCS, the appraisal
documents state that they were prepared “for tax purposes” and
that they are valuing the properties as of the date of
contribution. However, the appraisals were made more than 3
years after the due date of petitioners’ tax return and therefore
were not timely. See sec. 1.170A-13(c)(3)(i)(A), Income Tax
Regs.
In addition to these defects, the Form 8283 attached to
petitioners’ tax return was not signed by an appraiser or by the
donee; it does not list the date of acquisition for either
property; and it does not state whether either contribution was
made by means of a bargain sale or indicate that petitioners
received payments from DALPF.6 See sec. 1.170A-13(c)(4)(i) and
(ii), Income Tax Regs.
6 In their motion for partial summary judgment, petitioners
assert that the sale of development rights to DALPF was a bargain
sale. Petitioners have not explained why they failed to describe
it as such on the Form 8283, Noncash Charitable Contributions.
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