- 34 - (4) Qualified appraisal.--The term “qualified appraisal” means an appraisal prepared by a qualified appraiser which includes— (A) a description of the property appraised, (B) the fair market value of such property on the date of contribution and the specific basis for the valuation, (C) a statement that such appraisal was prepared for income tax purposes, (D) the qualifications of the qualified appraiser, (E) the signature and TIN of such appraiser, and (F) such additional information as the Secretary prescribes in such regulations. See Bond v. Commissioner, 100 T.C. 32, 37 (1993). In Bond this Court considered whether certain aspects of the above- referenced regulations were mandatory or directory and whether the taxpayer in that case had substantially complied so as to be entitled to a charitable contribution deduction. In reaching the conclusion that the requirements were directory, the Court expressed the following rationale: Under the above test we must examine section 170 to determine whether the requirements of the regulations are mandatory or directory with respect to its statutory purpose. At the outset, it is apparent that the essence of section 170 is to allow certain taxpayers a charitable deduction for contributions made to certain organizations. It is equally apparent that the reporting requirements of section 1.170A-13, Income Tax Regs., are helpful to respondent in the processing and auditing of returns on which charitable deductionsPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 NextLast modified: March 27, 2008