- 47 - statutorily mandated regulatory requirements. Bond v. Commissioner, 100 T.C. 32 (1993), and Hewitt v. Commissioner, 109 T.C. 258 (1997), considered together, provide a standard by which we can consider whether petitioners provided sufficient information to permit respondent to evaluate their reported contributions, as intended by Congress. If they provided sufficient information, their “substantial compliance” would adequately serve the purposes intended by Congress. We hold that petitioners did not provide sufficient information and/or submit the documents required to have substantially complied and they are, therefore, not entitled to deductions for noncash charitable contributions of FLP interests, as determined by respondent. Petitioners, in each year under consideration, did not attach to their returns qualified summary appraisal reports as required by the statute and the regulations. In addition, it has not been shown that petitioners’ C.P.A. was a qualified appraiser within the meaning of the regulatory requirements. Moreover, certain of the reports that were referenced on the returns were not shown to exist, and none of the purported reports or documentation submitted met the time requirements for their preparation and submission. The contributed property interests were not fully or adequately described so as to permit respondent to understand the valuation methodology, and the documentation submitted was terse and did not adequately explain the bases for the values claimed.Page: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 NextLast modified: March 27, 2008