Rhett Rance Smith and Alice Avila Smith, et al. - Page 32




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               Additionally, for contributions of $250 or more, a taxpayer            
          must obtain a contemporaneous written acknowledgment from the               
          donee organization.  Sec. 170(f)(8)(A).  The acknowledgment must            
          be obtained by the earlier of the date the return is filed or its           
          due date.  Sec. 170(f)(8)(C).  The acknowledgment must include              
          the amount of cash and a description of any property other than             
          cash along with certain information about any goods or services             
          provided by the donee.  Sec. 170(f)(8)(B).                                  
               The purpose of these provisions has been described as                  
          providing the Commissioner with sufficient return information to            
          effectively monitor the possibility of overvaluations of                    
          charitable contributions.  Hewitt v. Commissioner, supra at 265.            
               Section 1.170A-13(c)(3)(i) and (ii), Income Tax Regs.,                 
          contains the specific requirements that a “qualified appraisal”             
          must:                                                                       
               (1) Be made not earlier than 60 days before the date of the            
          contribution nor later than the due date of the return, including           
          extensions, on which a deduction is first claimed or reported;              
               (2) be prepared, signed and dated by a qualified appraiser;            
               (3) contain the name address, identifying number, and                  
          qualifications of the qualified appraiser;                                  
               (4) contain a statement that it was prepared for income tax            
          purposes;                                                                   
               (5) contain a description of the property in sufficient                
          detail for a person who is not generally familiar with the type             





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