Deloitte Tax Suggests Change to Proposed Charitable Substantiation Regs

Deloitte Tax Suggests Change to Proposed Charitable Substantiation Regs

News story posted in Regulations on 13 November 2008| comments
audience: National Publication | last updated: 18 May 2011


Writing on behalf of Deloitte Tax LLP, Laura Peebles has suggested that proposed regulations that would require attaching a complete appraisal with Form 8283 in any year in which an income tax charitable contribution deduction is carried over be removed and that including a copy of prior years' Forms 8283 would be sufficient.

Full Text: 

CC:PA:LPD:PR (REG-140029-07)
Room 5203
Internal Revenue Service
PO Box 7604, Ben Franklin Station
Washington DC 20044

Re: Proposed Regulations under Section 170

Dear Sir or Madam:

We appreciate the opportunity to provide comments on the proposed regulations covering certain recordkeeping requirements for charitable contributions.

We have one suggestion in the interest of reducing paperwork and processing efficiency. The proposed regulations require that a Form 8283 and a complete appraisal be attached in any year of a charitable contribution carryover. In the interest of paperwork reduction and facilitating electronic filing, we suggest that the requirement to attach a copy of the appraisal for carryover years be removed. Including a copy of the prior years' Forms 8283 is sufficient to alert the Service that a property contribution is included in the taxpayer's charitable contribution carryover. The electronic filing transmittal form already includes the ability to attach a Form 8283, so adding the ability to attach prior years' forms is unlikely to require significant additional work by the Service or tax return preparers. However, many appraisals, especially those involving real estate or tangible property are dozens or even hundreds of pages, making manually filed returns very bulky and as a practical matter precluding electronic filing. In addition, many qualified appraisals include color photographs or foldouts such as maps or diagrams, making them difficult to copy, and then difficult to read once copied in black and white on standard sized paper.

If you have any questions about this, please contact the undersigned at (202) 879-5320.

Very truly yours,

Laura Peebles
Private Client Advisors
Deloitte Tax LLP
Washington, D.C.

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