- 78 - several taxable years. We must decide whether petitioners are liable for the accuracy-related penalties with respect to the noncash charitable contribution deductions. Beginning in the mid-1990s and for various years through 2001, petitioners claimed deductions for noncash charitable contributions. Respondent determined that they are not entitled to the deductions because they failed to supply the information required by the statute and regulations, and we have so held.9 Respondent contends that petitioners knew that they had not supplied the required information--i.e., that the appraisals valued Beneco stock rather than the limited partnership interests and that the appraisals submitted were not timely as required by the statute. Amongst other errors in reporting the noncash charitable contributions, the percentages of ownership were misstated, the C.P.A. signed the appraiser’s name, and reference was made to an appraisal with a particular date which has not been shown to exist. Respondent contends that no reasonably prudent person would have allowed these errors to persist year after year. 9 Respondent also questioned whether the values of the limited partnership interests or the amounts of the claimed contributions were overstated. We have not addressed the value question because we have sustained respondent’s determination that petitioners are not entitled to any deduction because they failed to provide information required by the statute and the regulations.Page: Previous 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 NextLast modified: March 27, 2008