Rhett Rance Smith and Alice Avila Smith, et al. - Page 33




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          of property to ascertain that the property that was appraised is            
          the property that was contributed;                                          
               (6) include the terms of any agreement of understanding                
          entered into or expected to be entered into by or on behalf of              
          the donor or donee that relates to the use, sale, or other                  
          disposition of the property, including an agreement that                    
          restricts temporarily or permanently a donee’s right to dispose             
          of the property;                                                            
               (7) show the date on which the property was contributed;               
               (8) show the fair market value of the property on the date             
          of contribution;                                                            
               (9) show the method of valuation and the specific bases for            
          the valuation; and                                                          
               (10) show the date on which the appraisal was made.                    
               The Secretary promulgated the above-referenced regulations             
          in response to the Deficit Reduction Act of 1984 (DEFRA), Pub. L.           
          98-369, sec. 155(a), 98 Stat. 691.  DEFRA section 155 instructs             
          the Secretary to provide heightened substantiation reporting                
          requirements for certain noncash charitable contributions.  DEFRA           
          section 155 provides:                                                       
                    (3) Appraisal summary.--For purposes of this                      
               subsection, the appraisal summary shall be in such form and            
               include such information as the Secretary prescribes by                
               regulations.  Such summary shall be signed by the qualified            
               appraiser preparing the qualified appraisal and shall                  
               contain the TIN of such appraiser. Such summary shall be               
               acknowledged by the donee of the property appraised in such            
               manner as the Secretary prescribes in such regulations.                






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