- 44 - 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 wasPage: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 NextLast modified: March 27, 2008