Festus E. Obiakor and Paulene Harris Obiakor - Page 7




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          be allowed if these requirements are not satisfied.  Sec. 1.170A-           
          13(c)(2), Income Tax Regs.                                                  
               A qualified appraisal is an appraisal document that:  (1)              
          Relates to an appraisal that is made no earlier than 60 days                
          before the date of contribution of the appraised property or                
          later than the due date of the return on which a deduction is               
          first claimed; (2) is prepared, signed, and dated by a qualified            
          appraiser; (3) includes a statement that the appraisal was                  
          prepared for income tax purposes; and (4) includes the appraised            
          fair market value of the property on the date (or expected date)            
          of contribution.                                                            
               A qualified appraiser is an individual who includes on the             
          appraisal summary a declaration that: (1) The individual either             
          holds himself or herself out to the public as an appraiser or               
          performs appraisals regularly; (2) the appraiser is qualified to            
          make appraisals of the type of property being valued; and (3) the           
          appraiser understands that an intentionally false or fraudulent             
          overstatement of the value of the property described in the                 
          qualified appraisal or appraisal summary may subject the                    
          appraiser to civil penalty under section 6701 for aiding and                
          abetting an understatement of income tax liability.  Sec. 1.170A-           
          13(c)(5)(i)(A), (B), (D), Income Tax Regs.  An individual is not            
          a qualified appraiser if the individual is the donor, the donee,            
          any person employed by the donor or donee, or an appraiser who is           







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