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mandatory,” but “nothing in Bond * * * relieves * * * [the
taxpayers] of the requirement of obtaining a qualified
appraisal.” Hewitt v. Commissioner, supra at 263-264. Although
the value of the stock was not in dispute, the qualified
appraisal requirement is imposed by DEFRA section 155. Id. at
264. The doctrine of substantial compliance could not excuse the
taxpayers’ failure to comply with that requirement. Id. at 265-
266.
In D’Arcangelo v. Commissioner, supra, the taxpayers donated
art supplies to a high school and claimed a charitable
contribution deduction. The taxpayers attached a Form 8283 to
their tax return along with a “letter of appraisal” from the high
school principal. At trial, the taxpayers also introduced expert
testimony concerning the value of the donated property.
The Court held that the taxpayers had failed to obtain a
qualified appraisal and, therefore, had not substantially
complied with the regulations. The principal was not a qualified
appraiser because he was employed by the donee and did not
regularly perform appraisals. The taxpayers’ expert witness
performed only a cursory inspection of the donated items several
years before the date of contribution, and he was generally
unfamiliar with the condition of the items as of that date. We
stated that, unlike the taxpayers in Bond, the taxpayers “did not
merely fail to attach evidence of a qualified appraisal, they
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