Rhett Rance Smith and Alice Avila Smith, et al. - Page 44




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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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