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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.
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Last modified: March 27, 2008