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days before any of the contributions and ending on the due dates
of the corresponding returns. See sec. 1.170A-13(c)(3)(i)(A),
Income Tax Regs. Additionally, the 1995 report by Mr. Kramer did
not specifically state that it was prepared for income tax
purposes. See sec. 1.170A-13(c)(3)(ii)(G), Income Tax Regs. The
appraisal reports did not contain the dates (or expected dates)
of the contributions of the interests in the FLPs to the donee or
the values on these dates. See sec. 1.170A-13(c)(3)(ii)(C), (I),
Income Tax Regs. Respondent, referencing section 1.170A-
13(c)(3)(ii)(D), Income Tax Regs., also notes that the
restrictions on the donee’s right to use or dispose of the
donated property, as set forth in the partnership agreements, and
purchase and sale agreements, were not disclosed.
The Forms 8283 and the documents attached to petitioners’
returns failed to comply with the section 1.170A-13(c)(4), Income
Tax Regs., requirements that an appraisal summary be signed and
dated by a qualified appraiser who prepared the qualified
appraisal and include the information specified in section
1.170A-13(c)(4)(ii), Income Tax Regs. That regulation section
requires that the summary contain, inter alia, a description of
the property in sufficient detail for a person who is not
generally familiar with the type of property to ascertain that
the property that was appraised is the property that was
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