Rhett Rance Smith and Alice Avila Smith, et al. - Page 47




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          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.                    





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