Understanding Your Appraisals
But Wait – There’s More! Valuation and Legal Aspects of Charitable Contributions
The price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts. US - 26 CFR § 1.170A-1 (c) (2)
2
The fair market value of the property taken is the highest price on the date of valuation that would be agreed to by a seller, being willing to sell but under no particular or urgent necessity for so doing, nor obliged to sell, and a buyer, being ready, willing, and able to buy but under no particular necessity for so doing, each dealing with the other with full knowledge of all the uses and purposes for which the property is reasonably adaptable and available. Not For IRS Use California Code, Code of Civil Procedure - CCP § 1263.320
3
The highest price, expressed in terms of money, that a property would bring in an open and unrestricted market between a willing buyer and a willing seller who are both knowledgeable, informed, and prudent, and who are acting independently of each other Canada - The above definition stems from the decision of Cattanach, J. in Henderson v. Minister of National Revenue, 1973 Carswell Nat 189, [1973] C.T.C. 636, 73 D.T.C. 5471 4
Terminology • Internal Revenue Code • Law • Enacted by Congress in Title 26 of the United States Code (26 USC or Internal Revenue Code)
• Regulations • Treasury’s interpretations of the Internal Revenue Code • Code of Federal Regulations (26 CFR)
• Publications • Public Explanations
5
How Objects Enter into Museum Collections Typical Full or Fractional Title Transfers • Full gifts: Full title transfer • Partial gift: Percentage of title transfers (Fractional Interest) • Bequests: Full or Percentage of title transfers at death • Bargain sales: Part sale - Part Non-Cash Charitable Contribution 6
How Objects Enter into Museum Collections OTHER • Purchase: Full title transfer • Promised Gift: No title transfer • By Exchange: A purchase made with monies received by deaccessioning or through an exchange of objects • Restricted gifts: Monies to purchase specific objects • Abandoned Loan: Directed by state statutes
7
When Would a Museum Assign a Value to an Item?
8
• Insurance • Bargain Sale
• Form 990 Preparation • Contemporaneous Written Acknowledgment
9
INSURANCE Declared Values
• Risk Management • Loans 10
BARGAIN SALE • A bargain sale of property is a sale to a charity for less than the property's fair market value
• A bargain sale to a charity is • in part a charitable contribution • in part a sale or exchange 11
Bargain Sale – Charitable Intent • Donor with “charitable intent” sells a property to a charity for less than its FMV
• Donor gets a qualified appraisal from a qualified appraiser • Donor claims the difference between the FMV and the sales price as a deduction – this constitutes the charitable contribution
12
Example of Credit lines from Bargain Sale Financed by Donated Funds Bargain Sales can sometimes be inferred through credit lines
Robert Motherwell American, 1915-1991 Wall Painting with Stripes, 1944 Oil on canvas 137.2 x 170.5 cm (54 x 67-1/8 in.)
Restricted gift of Muriel Kallis Steinberg Newman in honor of her grandchildren, Ellen Steinberg and Peter Steinberg; gift of Lannan Foundation 1997.161 13
FORM 990 PREPARATION • Form 990 - Return of Organization Exempt from Tax • Annual information return filed by charities • Parts of the return are made available to the public
14
• Contemporaneous Written Acknowledgment
Donee that gives anything of value back to Donor must value it
15
Contributions Unrestricted versus
Restricted Affects Fair Market Value 16
Gift with Restrictions • If a Donor places a restriction on the disposition or use of the donated property, the FMV must reflect that restriction • Restrictions may impact FMV conclusion • Any restrictions on the donation must be disclosed in the Appraisal Report • Appraisers must know about restrictions so will ask the Donee for a copy of the Deed of Gift IRS 561 Publication, pg. 2
17
Non-Cash Charitable Contributions with Restrictions
• Appraiser will ask the Donee if the donation carries any restriction
18
Title Transfer/Date of Contribution
Offer In Writing Possession Acceptance in Writing
19
EXACTLY WHEN IS Title Transfer/Date of Contribution? • Determined by
State Law
• Which should then be in the collection management policy
20
Title Transfer Date • What is the official date of contribution?
– The date that the Donee takes possession? – The date the Donor signs the deed? – The date the countersigned deed is returned to the Donee? – The date of the Board of Trustees meeting?
21
Deeds of Gift
Instrument of Transfer? Suggestion – send deeds for signature PRIOR to Board of Trustees or Collection Committee Meeting 22
Hypothetical Timeline Donor offers gift to Donee in written form
Donee takes Possession
May 1
May 1
Board of Trustee Approval Acceptance letter and Deed of gift sent to Donor
Date of delivery
June 1
Most museums go with this date
Donor Returns Counter-Signed Deed of Gift
December 1
Some museums go with this date 23
Contemporaneous Written Acknowledgment • Donee should send (in a separate letter): • Contemporaneous Written Acknowledgment to confirm that the charity provided “no goods or services” in exchange for contribution for gifts value at $250 or more • Burden on the Donor to obtain a Contemporaneous Written Acknowledgment before the Donor files tax return
26 USC § 170(f)(8)
26 CFR 1.170A-13(f)(2)(ii)
24
Contemporaneous Written Acknowledgment
• Contemporaneous Written Acknowledgment must include: • Description of donated property • Whether or not the Donee provided goods or services in exchange • If the Donee did, a good faith estimate of the value of those goods or services
26 USC § 170(f)(8)
25
Understanding the 60-Day Rule
Appraisals Before Donation
26
Timing of a Qualified Appraisal • An appraisal cannot be made earlier than 60 days before the date of contribution of the appraised property, and no later than the due date of the return on which the deduction is claimed
• When does the clock start ticking for the 60 days?
27
Hypothetical Timeline Gift offered to Donee April 1
Gift delivered to Donee August 1
Donee approves gift and informs Donor Sept 1
Countersigned Deed of Gift returned Nov 1
Which is the date when the 60 days limit prior to the date of the contribution goes into effect?
28
Hypothetical Timeline Gift offered to Donee April 1
Gift delivered to Donee August 1
Donee approves gift and informs Donor Sept 1
Countersigned Deed of Gift returned Nov 1
Tick Tock -60 days before this date • 60 days prior to the effective date (date of contribution/title transfer)
• Donor would get a Prospective appraisal concluding what the fair market value is expected to be and the appraisal would be based on an “extraordinary assumption “ the market will not significantly change
29
Will a Donor Receive a Fair Market Value Deduction for a Charitable Contribution? A qualified appraisal by a qualified appraiser is almost always needed for a claimed contribution deduction of over $5,000 • If Long-Term Capital Gain Property
• Donor can deduct FMV with some exceptions • If Short-Term Capital Gain Property (Ordinary Income Property) • Donor can deduct Cost Basis or FMV, whichever is less
30
ARCHIVES • Gifts of Archives to Museums
31
Ordinary Income Treatment Examples of Ordinary Income • • • •
Owned for one year or less Held as inventory by an art dealer Donated by the artist Donated by a Donor who received it as a gift from the artist • Gifted to a charity for an unrelated use
IRS Publication 526
32
Unrelated Use •
• •
Common example of unrelated use • Sale by charity at charity auction Recapture Rule • When there is unrelated use/no exempt use Certification by charity will prevent operation of Recapture Rule
26 US Code § 170 (e) (7) Enacted in Pension Protection Act of 2006
33
3-Year Rule Letter of Intent Deed of Gift XXX Museum will not sell, donate, exchange, or otherwise dispose of gifts accessioned into the permanent collection until a minimum of three years after the date of receipt… 34
COPIES OF APPRAISALS TO DONEES
35
What is the Rule? A leading Publication states "The instructions also require that after June 6, 1988, the donor must provide the donee with a copy of the qualified appraisal.”
36
Appraisal Summary = IRS Form 8283 • Statement to be furnished by Donors to Donees • “Every donor who presents an appraisal summary to a donee for signature after June 6, 1988, in order to comply with paragraph (c)(4)(i)(B) of this section shall furnish a copy of the appraisal summary to such donee.” 26 CFR § 1.170A-13(c)(4)(iv)(E)
However, FMV does NOT have to be included on the appraisal summary (8283) when it is provided to the Donee
26 CFR § 1.170A-13(c)(4)(iv)(D) and Form 8283 instructions, pg. 7 37
Appraiser Providing an Appraisal to the Donee
• The Donee is not an Intended User (assuming the Donee is not the appraiser’s client) • May be harmless if the Donee uses a value from an appraisal to determine the total “declared” value of a collection • May be harmful if a Donee uses an appraiser’s concluded FMV on a loan agreement and there is a loss • Donee would probably not be fully covered for a timely replacement
38
The Pension Protection Act
August 17, 2006
39
Taxidermy Contributions • Gardner v. Commissioner
TC Memo. 2017-165, filed August. 24, 2017.
40
GIFTS OF A FRACTIONAL INTEREST Sometimes referred to as a “Partial Gift”
26 CFR § 1.170A-7(b)(1) 41
FRACTIONAL INTEREST in Non-Cash Contributions • If you make an additional contribution later, the fair market value of that contribution will be determined by using the smaller of: • The FMV of the property at the time of the initial contribution, or • The FMV of the property at the time of the additional contribution 26 USC § 170 (o) special rule for fractional gifts Publication 526, Cat. No. 15050A 42
HR 4 Technical Explanation • Joint Committee on Taxation’s explanation of changes made by the PPA
• A contribution made before the date of enactment of the PPA is not to be treated as the initial fractional contribution – Instead the first fractional contribution after the date of enactment is considered the initial fractional contribution
http://www.jct.gov/x-38-06.pdf 43
Hypothetical Timeline Donor gives 10%
Donor gives an additional 50%
Donor gives final 40%
May 1, 2004
May 1, 2007
May 1, 2016
Initial Contribution
Tick Tock - PPA invoked
Donor deducts FMV from 2007 or 2016, whichever is less 44
Hypothetical Timeline Donor gives 10%
Donor gives an additional 50%
Donor gives final 40 %
May 1, 2004
May 1, 2005
May 1, 2016
Initial Contribution
Prior to PPA
Tick Tock -PPA invoked Donor deducts FMV from 2016 since 60% is grandfathered in 45
Hypothetical Timeline Full gift must be transferred 100% by May 1, 2017 or by date of Donor’s death, whichever comes first
Donor gives 10%
Donor gives 15%
Donor gives 10%
Donor gives 15%
May 1, 2007
May 1, 2008
May 1, 2009
May 1, 2010 May 1, 2012 May 1, 2016
Tick Tock - PPA Invoked Initial Contribution
Donor deducts FMV from 2007 or 2008 whichever is less
Donor deducts FMV from 2007 or 2009 whichever is less
Donor deducts FMV from 2007 or 2010 whichever is less
Donor gives 30%
Donor gives 10%
Donor deducts Donor deducts FMV from FMV from 2007 or 2012 2007 or 2016 whichever whichever is less is less
46
IRS Form 8283 Donee Acknowledgment - Part IV •
Date the charitable organization received the donated property This means the Date of Title Transfer - Not Possession • The Donee could have had the property on the premises for years as a Promised Gift or Extended Loan
• Related or Unrelated Use • Use is either related (Permanent Collection) or unrelated (Auction) to the exempt purpose or function of the charitable organization
https://www.irs.gov/pub/irs-pdf/f8283.pdf - revised December 2014
47
IRS Form 8282 Donee Information Return • Donee uses this form to report to the IRS and Donors about dispositions of property within 3 years of the contribution date • It is a disposition if the Donee sells, exchanges, consumes or otherwise disposes of the donated property
https://www.irs.gov/pub/irs-pdf/f8282.pdf - revised April 2009 48
Lela Hersh, ASA [email protected] 847.780.4560
© 2017 Lela Hersh
Museum and Fine Arts Consulting, LLC Art Advisor Chicago Accredited Senior Appraiser, American Society of Appraisers ASA International Personal Property Discipline Chair Lecturer, Graduate Department of Arts Administration and Policy, School of the Art Institute of Chicago
49
References • • • • • • • • • • • • •
HR 4 Technical Explanation, http://www.jct.gov/x-38-06.pdf Instructions for Form 8283 http://www.irs.gov/pub/irs-pdf/i8283.pdf Instructions for Form 8282 https://www.irs.gov/forms-pubs/form-8282-donee-information-return Instructions for Form 990 https://www.irs.gov/instructions/i990 IRS Form 8283 https://www.irs.gov/pub/irs-pdf/f8283.pdf IRS Form 8282 https://www.irs.gov/pub/irs-pdf/f8282.pdf IRS Publication 526, Charitable Contributions IRS Publication 561, Determining the Value of Donated Property IRS Publication 1771, Charitable Contributions, Substantiation and Disclosure Requirements IRS Art Appraisal Services, http://www.irs.gov/Individuals/Art-Appraisal-Services Malaro, Marie C., and Ildiko Pogány DeAngelis. A Legal Primer on Managing Museum Collections. Washington, DC: Smithsonian Books, 2012, third edition. 26 USC § 170 26 CFR § 1.170A-13 – requirements of a qualified appraisal for a charitable contribution
50
The price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts. US - 26 CFR § 1.170A-1 (c) (2)
2
The fair market value of the property taken is the highest price on the date of valuation that would be agreed to by a seller, being willing to sell but under no particular or urgent necessity for so doing, nor obliged to sell, and a buyer, being ready, willing, and able to buy but under no particular necessity for so doing, each dealing with the other with full knowledge of all the uses and purposes for which the property is reasonably adaptable and available. Not For IRS Use California Code, Code of Civil Procedure - CCP § 1263.320
3
The highest price, expressed in terms of money, that a property would bring in an open and unrestricted market between a willing buyer and a willing seller who are both knowledgeable, informed, and prudent, and who are acting independently of each other Canada - The above definition stems from the decision of Cattanach, J. in Henderson v. Minister of National Revenue, 1973 Carswell Nat 189, [1973] C.T.C. 636, 73 D.T.C. 5471 4
Terminology • Internal Revenue Code • Law • Enacted by Congress in Title 26 of the United States Code (26 USC or Internal Revenue Code)
• Regulations • Treasury’s interpretations of the Internal Revenue Code • Code of Federal Regulations (26 CFR)
• Publications • Public Explanations
5
How Objects Enter into Museum Collections Typical Full or Fractional Title Transfers • Full gifts: Full title transfer • Partial gift: Percentage of title transfers (Fractional Interest) • Bequests: Full or Percentage of title transfers at death • Bargain sales: Part sale - Part Non-Cash Charitable Contribution 6
How Objects Enter into Museum Collections OTHER • Purchase: Full title transfer • Promised Gift: No title transfer • By Exchange: A purchase made with monies received by deaccessioning or through an exchange of objects • Restricted gifts: Monies to purchase specific objects • Abandoned Loan: Directed by state statutes
7
When Would a Museum Assign a Value to an Item?
8
• Insurance • Bargain Sale
• Form 990 Preparation • Contemporaneous Written Acknowledgment
9
INSURANCE Declared Values
• Risk Management • Loans 10
BARGAIN SALE • A bargain sale of property is a sale to a charity for less than the property's fair market value
• A bargain sale to a charity is • in part a charitable contribution • in part a sale or exchange 11
Bargain Sale – Charitable Intent • Donor with “charitable intent” sells a property to a charity for less than its FMV
• Donor gets a qualified appraisal from a qualified appraiser • Donor claims the difference between the FMV and the sales price as a deduction – this constitutes the charitable contribution
12
Example of Credit lines from Bargain Sale Financed by Donated Funds Bargain Sales can sometimes be inferred through credit lines
Robert Motherwell American, 1915-1991 Wall Painting with Stripes, 1944 Oil on canvas 137.2 x 170.5 cm (54 x 67-1/8 in.)
Restricted gift of Muriel Kallis Steinberg Newman in honor of her grandchildren, Ellen Steinberg and Peter Steinberg; gift of Lannan Foundation 1997.161 13
FORM 990 PREPARATION • Form 990 - Return of Organization Exempt from Tax • Annual information return filed by charities • Parts of the return are made available to the public
14
• Contemporaneous Written Acknowledgment
Donee that gives anything of value back to Donor must value it
15
Contributions Unrestricted versus
Restricted Affects Fair Market Value 16
Gift with Restrictions • If a Donor places a restriction on the disposition or use of the donated property, the FMV must reflect that restriction • Restrictions may impact FMV conclusion • Any restrictions on the donation must be disclosed in the Appraisal Report • Appraisers must know about restrictions so will ask the Donee for a copy of the Deed of Gift IRS 561 Publication, pg. 2
17
Non-Cash Charitable Contributions with Restrictions
• Appraiser will ask the Donee if the donation carries any restriction
18
Title Transfer/Date of Contribution
Offer In Writing Possession Acceptance in Writing
19
EXACTLY WHEN IS Title Transfer/Date of Contribution? • Determined by
State Law
• Which should then be in the collection management policy
20
Title Transfer Date • What is the official date of contribution?
– The date that the Donee takes possession? – The date the Donor signs the deed? – The date the countersigned deed is returned to the Donee? – The date of the Board of Trustees meeting?
21
Deeds of Gift
Instrument of Transfer? Suggestion – send deeds for signature PRIOR to Board of Trustees or Collection Committee Meeting 22
Hypothetical Timeline Donor offers gift to Donee in written form
Donee takes Possession
May 1
May 1
Board of Trustee Approval Acceptance letter and Deed of gift sent to Donor
Date of delivery
June 1
Most museums go with this date
Donor Returns Counter-Signed Deed of Gift
December 1
Some museums go with this date 23
Contemporaneous Written Acknowledgment • Donee should send (in a separate letter): • Contemporaneous Written Acknowledgment to confirm that the charity provided “no goods or services” in exchange for contribution for gifts value at $250 or more • Burden on the Donor to obtain a Contemporaneous Written Acknowledgment before the Donor files tax return
26 USC § 170(f)(8)
26 CFR 1.170A-13(f)(2)(ii)
24
Contemporaneous Written Acknowledgment
• Contemporaneous Written Acknowledgment must include: • Description of donated property • Whether or not the Donee provided goods or services in exchange • If the Donee did, a good faith estimate of the value of those goods or services
26 USC § 170(f)(8)
25
Understanding the 60-Day Rule
Appraisals Before Donation
26
Timing of a Qualified Appraisal • An appraisal cannot be made earlier than 60 days before the date of contribution of the appraised property, and no later than the due date of the return on which the deduction is claimed
• When does the clock start ticking for the 60 days?
27
Hypothetical Timeline Gift offered to Donee April 1
Gift delivered to Donee August 1
Donee approves gift and informs Donor Sept 1
Countersigned Deed of Gift returned Nov 1
Which is the date when the 60 days limit prior to the date of the contribution goes into effect?
28
Hypothetical Timeline Gift offered to Donee April 1
Gift delivered to Donee August 1
Donee approves gift and informs Donor Sept 1
Countersigned Deed of Gift returned Nov 1
Tick Tock -60 days before this date • 60 days prior to the effective date (date of contribution/title transfer)
• Donor would get a Prospective appraisal concluding what the fair market value is expected to be and the appraisal would be based on an “extraordinary assumption “ the market will not significantly change
29
Will a Donor Receive a Fair Market Value Deduction for a Charitable Contribution? A qualified appraisal by a qualified appraiser is almost always needed for a claimed contribution deduction of over $5,000 • If Long-Term Capital Gain Property
• Donor can deduct FMV with some exceptions • If Short-Term Capital Gain Property (Ordinary Income Property) • Donor can deduct Cost Basis or FMV, whichever is less
30
ARCHIVES • Gifts of Archives to Museums
31
Ordinary Income Treatment Examples of Ordinary Income • • • •
Owned for one year or less Held as inventory by an art dealer Donated by the artist Donated by a Donor who received it as a gift from the artist • Gifted to a charity for an unrelated use
IRS Publication 526
32
Unrelated Use •
• •
Common example of unrelated use • Sale by charity at charity auction Recapture Rule • When there is unrelated use/no exempt use Certification by charity will prevent operation of Recapture Rule
26 US Code § 170 (e) (7) Enacted in Pension Protection Act of 2006
33
3-Year Rule Letter of Intent Deed of Gift XXX Museum will not sell, donate, exchange, or otherwise dispose of gifts accessioned into the permanent collection until a minimum of three years after the date of receipt… 34
COPIES OF APPRAISALS TO DONEES
35
What is the Rule? A leading Publication states "The instructions also require that after June 6, 1988, the donor must provide the donee with a copy of the qualified appraisal.”
36
Appraisal Summary = IRS Form 8283 • Statement to be furnished by Donors to Donees • “Every donor who presents an appraisal summary to a donee for signature after June 6, 1988, in order to comply with paragraph (c)(4)(i)(B) of this section shall furnish a copy of the appraisal summary to such donee.” 26 CFR § 1.170A-13(c)(4)(iv)(E)
However, FMV does NOT have to be included on the appraisal summary (8283) when it is provided to the Donee
26 CFR § 1.170A-13(c)(4)(iv)(D) and Form 8283 instructions, pg. 7 37
Appraiser Providing an Appraisal to the Donee
• The Donee is not an Intended User (assuming the Donee is not the appraiser’s client) • May be harmless if the Donee uses a value from an appraisal to determine the total “declared” value of a collection • May be harmful if a Donee uses an appraiser’s concluded FMV on a loan agreement and there is a loss • Donee would probably not be fully covered for a timely replacement
38
The Pension Protection Act
August 17, 2006
39
Taxidermy Contributions • Gardner v. Commissioner
TC Memo. 2017-165, filed August. 24, 2017.
40
GIFTS OF A FRACTIONAL INTEREST Sometimes referred to as a “Partial Gift”
26 CFR § 1.170A-7(b)(1) 41
FRACTIONAL INTEREST in Non-Cash Contributions • If you make an additional contribution later, the fair market value of that contribution will be determined by using the smaller of: • The FMV of the property at the time of the initial contribution, or • The FMV of the property at the time of the additional contribution 26 USC § 170 (o) special rule for fractional gifts Publication 526, Cat. No. 15050A 42
HR 4 Technical Explanation • Joint Committee on Taxation’s explanation of changes made by the PPA
• A contribution made before the date of enactment of the PPA is not to be treated as the initial fractional contribution – Instead the first fractional contribution after the date of enactment is considered the initial fractional contribution
http://www.jct.gov/x-38-06.pdf 43
Hypothetical Timeline Donor gives 10%
Donor gives an additional 50%
Donor gives final 40%
May 1, 2004
May 1, 2007
May 1, 2016
Initial Contribution
Tick Tock - PPA invoked
Donor deducts FMV from 2007 or 2016, whichever is less 44
Hypothetical Timeline Donor gives 10%
Donor gives an additional 50%
Donor gives final 40 %
May 1, 2004
May 1, 2005
May 1, 2016
Initial Contribution
Prior to PPA
Tick Tock -PPA invoked Donor deducts FMV from 2016 since 60% is grandfathered in 45
Hypothetical Timeline Full gift must be transferred 100% by May 1, 2017 or by date of Donor’s death, whichever comes first
Donor gives 10%
Donor gives 15%
Donor gives 10%
Donor gives 15%
May 1, 2007
May 1, 2008
May 1, 2009
May 1, 2010 May 1, 2012 May 1, 2016
Tick Tock - PPA Invoked Initial Contribution
Donor deducts FMV from 2007 or 2008 whichever is less
Donor deducts FMV from 2007 or 2009 whichever is less
Donor deducts FMV from 2007 or 2010 whichever is less
Donor gives 30%
Donor gives 10%
Donor deducts Donor deducts FMV from FMV from 2007 or 2012 2007 or 2016 whichever whichever is less is less
46
IRS Form 8283 Donee Acknowledgment - Part IV •
Date the charitable organization received the donated property This means the Date of Title Transfer - Not Possession • The Donee could have had the property on the premises for years as a Promised Gift or Extended Loan
• Related or Unrelated Use • Use is either related (Permanent Collection) or unrelated (Auction) to the exempt purpose or function of the charitable organization
https://www.irs.gov/pub/irs-pdf/f8283.pdf - revised December 2014
47
IRS Form 8282 Donee Information Return • Donee uses this form to report to the IRS and Donors about dispositions of property within 3 years of the contribution date • It is a disposition if the Donee sells, exchanges, consumes or otherwise disposes of the donated property
https://www.irs.gov/pub/irs-pdf/f8282.pdf - revised April 2009 48
Lela Hersh, ASA [email protected] 847.780.4560
© 2017 Lela Hersh
Museum and Fine Arts Consulting, LLC Art Advisor Chicago Accredited Senior Appraiser, American Society of Appraisers ASA International Personal Property Discipline Chair Lecturer, Graduate Department of Arts Administration and Policy, School of the Art Institute of Chicago
49
References • • • • • • • • • • • • •
HR 4 Technical Explanation, http://www.jct.gov/x-38-06.pdf Instructions for Form 8283 http://www.irs.gov/pub/irs-pdf/i8283.pdf Instructions for Form 8282 https://www.irs.gov/forms-pubs/form-8282-donee-information-return Instructions for Form 990 https://www.irs.gov/instructions/i990 IRS Form 8283 https://www.irs.gov/pub/irs-pdf/f8283.pdf IRS Form 8282 https://www.irs.gov/pub/irs-pdf/f8282.pdf IRS Publication 526, Charitable Contributions IRS Publication 561, Determining the Value of Donated Property IRS Publication 1771, Charitable Contributions, Substantiation and Disclosure Requirements IRS Art Appraisal Services, http://www.irs.gov/Individuals/Art-Appraisal-Services Malaro, Marie C., and Ildiko Pogány DeAngelis. A Legal Primer on Managing Museum Collections. Washington, DC: Smithsonian Books, 2012, third edition. 26 USC § 170 26 CFR § 1.170A-13 – requirements of a qualified appraisal for a charitable contribution
50
