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regularly used by the donor or donee and who does not perform
most of his or her appraisals for other persons. Sec. 1.170A-
13(c)(5)(iv)(A), (C), (D), (F), Income Tax Regs.
An appraisal summary means a summary of a qualified
appraisal that: (1) Is made on the form prescribed by the
Internal Revenue Service (Form 8283), (2) is signed and dated by
the qualified appraiser who prepared the qualified appraisal, (3)
is signed and dated by the donee, and (4) includes, inter alia,
the following: a detailed description of the property; the manner
of acquisition of the property by the donor; the name, address,
and identifying number of the qualified appraiser who signs the
appraisal summary; and the appraised fair market value of the
property. Sec. 1.170A-13(c)(4)(i) and (ii), Income Tax Regs.
With respect to the noncash contributions at issue,
petitioners concede that they neither obtained a qualified
appraisal of the property that they donated to the Salvation
Army, nor did they attach a Form 8283 to the return for the
taxable year 2003. In this case, the only forms that petitioners
attached to their 2003 return were a receipt that petitioner
filled out and the aforementioned itemized list of the items
donated, which he also compiled. Neither the receipt nor the
itemized form meet the requirements prescribed under section
170(a), as they do not meet the requirements for a qualified
appraisal made by a qualified appraiser.
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Last modified: November 10, 2007