- 43 - of Appraiser was signed by Mr. Kramer, and references were made to a September 1, 1999, appraisal. Petitioners did not produce a September 1, 1999, appraisal report, and no such appraisal report was attached to their returns. The second appraisal was performed Mr. Koehl of Management Planning, Inc., a company in the valuation business. Mr. Koehl determined that the aggregate enterprise value of Beneco, on a controlling interest basis, was $8.5 million as of March 31, 2000. Mr. Koehl did not prepare a separate analysis or valuation of the partnership interests. His report appears to have been completed after the due date for filing petitioners’ 2000 returns. Forms 8283 for 2001 referred to Mr. Koehl’s valuation, and Rhett and Alice’s 2002 contribution was apparently based upon that same appraisal report by Mr. Koehl. Some of the returns had a one-page letter from Mr. Koehl that fell far short of meeting the statutory and regulatory requirements for an appraisal summary. Other returns had no letter, summary, or appraisal report attached. At trial, petitioners’ expert, Scott Springer, valued the partnership interests as of the dates of the contributions. This report, however, was prepared for purposes of trial and did not purport to be a qualified appraisal within the meaning of the regulations under consideration. Accordingly, the appraisals petitioners relied on for claiming deductions were not made for the period beginning 60Page: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 NextLast modified: March 27, 2008