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Abstract: 

A taxpayer who claims a charitable contribution deduction for a donation of property valued at more than $5,000 generally is required to obtain a qualified appraisal and attach an appraisal summary to the tax return on which the deduction is claimed. If the property contributed is valued at $500,000 or more, the qualified appraisal itself must be attached to the return when filed. This sounds fairly straightforward but, as always, following the rules matters. Two recent cases—Loube v. Commissioner and Presley v. Commissioner—illustrate the consequences of failing to comply with the appraisal requirements. We examine the facts and rulings in both of these important cases.

Keywords: IRC §170 Substantiation Requirements; Strict vs. Substantial Compliance; RERI Holdings I, LLC v. Commissioner; Deductions for Improvements Expenses

Affiliations:  1: Clark Hill PLC.