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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 60
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