Festus E. Obiakor and Paulene Harris Obiakor - Page 8




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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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