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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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